In the years since the pandemic reshaped workplace expectations, Connecticut has become a central battleground in the debate over whether remote work is a legal right or a workplace privilege. Employers and employees have struggled with the question of what qualifies as a reasonable accommodation under state and federal disability laws. A recent Connecticut Appellate Court ruling brings clarity to this issue.

Our employment law attorneys at Wofsey Rosen regularly counsel employers navigating these issues, and this decision offers significant guidance for organizations across the state. At its core, the ruling confirms that a request for full-time remote work is not a reasonable accommodation when it would remove essential job functions, reinforcing an employer’s authority to define a position’s core duties and setting essential limits on remote-work accommodation requests.

Background of the Decision

In Castelino v. Whitman, Breed, Abbott & Morgan, LLC, a paralegal with a compromised immune system requested to work remotely full-time to avoid potential COVID-19 exposure. Her employer denied the request, explaining that her job required hands-on responsibilities, such as retrieving physical files, securing ink signatures, and notarizing documents, which she could not perform from home.

After the employer denied her request, it terminated the employee, who then sued the firm for disability discrimination and failure to accommodate under the Connecticut Fair Employment Practices Act (CFEPA). The trial court granted summary judgment in favor of the employer, and the Appellate Court affirmed.

The Court’s Ruling

The decision centered on what qualifies as an essential function under the ADA and CFEPA. While employers must provide reasonable accommodations to qualified individuals with disabilities, an accommodation becomes legally unreasonable if it removes the core duties of the job. In evaluating the paralegal’s request, the court focused on:

• Employer’s judgment: The court gave substantial deference to the employer’s explanation of why certain duties required in-person work.
• Written job descriptions: The formal description of the paralegal’s role supported the employer’s position.
• Actual work performed: Even if in-person tasks did not consume most of the employee’s time, they were still fundamental to the proper functioning of the job.

Because the employee’s request for 100% remote work would have eliminated multiple essential duties, and because employers are not required to reassign essential tasks to others, the court held that her proposed accommodation was unreasonable as a matter of law.

This decision reinforces a key principle that remote work may be common, but it is not automatically a reasonable accommodation under disability law.

Key Takeaways for Connecticut Employers

The Castelino ruling is a significant win for employers, but it does not allow organizations to reject all work-from-home requests. Instead, it underscores the importance of clarity, documentation, and consistency.

Keep Job Descriptions Accurate and Specific

The court’s analysis relied heavily on the employer’s ability to explain why in-person work was necessary. Employers should review and update job descriptions to clearly identify duties requiring physical presence. Specific examples, such as client intake responsibilities, handling physical records, or notarizing documents, are more persuasive than general statements.

The Interactive Process is Still Required

Employers must continue to engage in a good-faith interactive process when an employee requests an accommodation. Castelino does not provide a shortcut to deny remote-work requests. Instead, employers should carefully evaluate:

• Whether the job truly requires in-person duties
• Whether those duties are essential
• Whether alternative accommodations, such as hybrid work, might allow the employee to perform all essential functions

If the essential functions can, in fact, be performed remotely, the outcome may differ from the court’s ruling in Castelino.

Consistency Matters

The court’s deference to the employer’s judgment depends on consistent practices. If an employer argues that in-person work is essential but allows other employees in similar roles to work remotely, that inconsistency can undermine the employer’s position. Uniform policies and consistent enforcement remain critical.

What This Means for Employers Going Forward

The Castelino decision provides valuable support for Connecticut employers requiring on-site attendance in roles that require physical presence. The ruling affirms that remote work is not automatically a reasonable accommodation and that employers are not required to restructure essential duties to allow remote schedules.

At the same time, employers must continue to follow established accommodation protocols and ensure that their job descriptions, policies, and practices align with the essential-function analysis the court endorsed.

Our Team at Wofsey Rosen Can Help Employers Ensure Compliance and Reduce Risk

Our employment law attorneys at Wofsey Rosen are dedicated to helping Connecticut businesses understand their rights and responsibilities. Navigating these regulations requires experience and a thorough understanding of relevant law to ensure that your workplace policies are legally sound. Contact us today for guidance on updating job descriptions, handling accommodation requests, or evaluating remote-work policies.