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