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230 Conn.App. 666
Conn. App. Ct.
2025
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Background

  • Kimberly Eldridge, a registered nurse, was employed by the Hospital of Central Connecticut and suffered from alcoholism and bipolar disorder.
  • She took medical leave under the FMLA and CFMLA for treatment, during which her nursing license was suspended by the Connecticut Board of Examiners for Nursing.
  • After exhausting her leave benefits and while her license remained suspended, Eldridge was terminated by the hospital.
  • Eldridge sued, alleging disability discrimination and failure to provide reasonable accommodation under the Connecticut Fair Employment Practices Act (CFEPA).
  • The trial court granted the hospital’s motion for summary judgment, finding no genuine issue of material fact and that the defendant’s reasons for termination were nondiscriminatory and unrefuted.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Disability discrimination Termination was due to disability; pretext inquiry improper where action was based on disability-related leave. Termination was due to failure to return and lost license, not disability; plaintiff offered no evidence of pretext. Summary judgment for defendant; legitimate, nondiscriminatory reasons given, no evidence of pretext.
Reasonable accommodation Sought leave and possibly reassignment; claims she made good faith request. No evidence of any request for accommodation prior to termination; no evidence of available reassignment position. Summary judgment for defendant; plaintiff did not initiate interactive process or identify available position.

Key Cases Cited

  • McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for discrimination claims)
  • Jackson v. Water Pollution Control Authority, 278 Conn. 692 (describes McDonnell Douglas framework in Connecticut)
  • Curry v. Allan S. Goodman, Inc., 286 Conn. 390 (Connecticut courts follow analogous federal antidiscrimination law)
  • Thomson v. Dept. of Social Services, 176 Conn. App. 122 (sets standards for proving failure to accommodate claims)
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Case Details

Case Name: Eldridge v. Hospital of Central Connecticut
Court Name: Connecticut Appellate Court
Date Published: Feb 11, 2025
Citations: 230 Conn.App. 666; 330 A.3d 604; AC46868
Docket Number: AC46868
Court Abbreviation: Conn. App. Ct.
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