Connecticut Fair Employment Practices Act — primary statute
Connecticut's primary workplace anti-discrimination statute is the Connecticut Fair Employment Practices Act (CFEPA), principally codified at Conn. Gen. Stat. § 46a-60. As of June 2026, § 46a-60 prohibits discriminatory employment practices by employers, labor organizations, and employment agencies based on the following protected characteristics:
- race
- color
- religious creed
- age
- sex
- gender identity or expression
- marital status
- national origin
- ancestry
- disability (including physical, mental, and learning disabilities)
- veteran status
- status as a victim of domestic violence (effective October 1, 2022 via Public Act 22-82)
- status as a victim of sexual assault (effective October 1, 2025 via Public Act 25-139)
- status as a victim of trafficking in persons (effective October 1, 2025 via Public Act 25-139)
Sexual orientation protections are implemented in a related statutory section, Conn. Gen. Stat. § 46a-81c. Section 46a-81c prohibits employment discrimination on the basis of sexual orientation, covering employers, employment agencies, and labor organizations. Claims under both § 46a-60 and § 46a-81c are subject to enforcement by the Connecticut Commission on Human Rights and Opportunities (CHRO).
Employers must comply with both statutes to ensure comprehensive workplace anti-discrimination coverage recognized under Connecticut law.
Source: Conn. Gen. Stat. § 46a-60 Source: Conn. Gen. Stat. § 46a-81c Source: 2022 Conn. Pub. Act No. 22-82 Source: 2025 Conn. Pub. Act No. 25-139 (sexual assault/trafficking protected class, eff. Oct. 1, 2025)
CFEPA employer size threshold — one or more employees
CFEPA applies to employers with one or more employees. Public Act 22-82, effective October 1, 2022, eliminated the prior three-employee threshold. The statute defines "employer" to include the state and all political subdivisions thereof and means any person with one or more persons in their employ. This is broader than Title VII's 15-employee minimum and makes Connecticut one of the most expansive state anti-discrimination laws by coverage.
Source: Conn. Gen. Stat. § 46a-51(10)
90-day deadline after CHRO release—mandatory, not jurisdictional, subject to waiver/tolling
90-day deadline after CHRO release—mandatory, not jurisdictional, subject to waiver/tolling
Connecticut law requires a complainant to file any lawsuit in Superior Court for employment discrimination within 90 days after receiving a release of jurisdiction (ROJ) from the Connecticut Commission on Human Rights and Opportunities (CHRO). This 90-day deadline is set by Conn. Gen. Stat. § 46a-101(e).
Statutory characterization: In 2021, the legislature amended § 46a-101(e) to clarify: "The ninety-day limitation period is mandatory, not subject matter jurisdictional, and is subject to waiver and equitable tolling."
Appellate holding: In Sokolovsky v. Mulholland (2022), the Connecticut Appellate Court addressed § 46a-101(e) directly and held:
- The 90-day post-ROJ deadline is mandatory—typically, missing it will result in dismissal.
- The deadline is not subject-matter jurisdictional—courts do not lose power to hear the case solely because the deadline lapsed.
- The deadline may be waived or tolled—courts retain the ability to excuse late filings upon a proper showing (for example, if the defendant waives the defense, or if equitable tolling applies).
Attorneys should not bank on tolling or waiver: these doctrines are narrowly applied. But a missed deadline is not fatal on jurisdictional grounds alone.
Source: Conn. Gen. Stat. § 46a-101 (see Chapter 814c, current official version) Source: Sokolovsky v. Mulholland, 213 Conn. App. 128 (2022)
CFEPA protection against sexual orientation discrimination
Connecticut law expressly prohibits employment discrimination based on sexual orientation under the Connecticut Fair Employment Practices Act (CFEPA). The primary basis for this protection is Conn. Gen. Stat. § 46a‑81c, which makes it unlawful for any employer, employment agency, or labor organization to refuse to hire, discharge, or otherwise discriminate in compensation or terms, conditions, or privileges of employment because of an individual’s sexual orientation. This also applies to apprenticeship/training programs and employment agency referrals.
Material Update—Definition Expanded (Effective July 1, 2023): Public Act 23‑145 significantly expanded the definition of "sexual orientation" in Conn. Gen. Stat. § 46a‑81a effective July 1, 2023. The statute now provides:
- “Sexual orientation means a person’s identity in relation to the gender or genders to which the person is romantically, emotionally or sexually attracted, inclusive of any identity that a person has previously expressed or that others perceive that person to hold.”
This update replaces the prior, narrower language focused on “heterosexuality, homosexuality or bisexuality” and covers perceived orientation, prior expressions, and any change in a person’s identity over time.
Statutory Scope and Enforcement:
- Conn. Gen. Stat. § 46a‑81c applies to all employers as defined in § 46a‑51(10) (one or more employees). There are no job-category exclusions. The Connecticut Commission on Human Rights and Opportunities (CHRO) is the enforcement agency and uses the same complaint procedures as for other CFEPA protected classes.
- While Conn. Gen. Stat. § 46a‑60 (the main anti-discrimination section) does not enumerate sexual orientation, CFEPA protections are extended to employment by §§ 46a‑81a to 46a‑81r, with § 46a‑81c controlling for workplace protection.
Source: Conn. Gen. Stat. § 46a‑81c Source: Conn. Gen. Stat. § 46a‑81a Source: 2023 Public Act No. 23‑145 (definition revision, eff. July 1, 2023) – see DAS Legislative Summary, p. 7
Connecticut individual-supervisor liability under CFEPA
Connecticut law allows individuals, including supervisors or managers, to be held personally liable under the Connecticut Fair Employment Practices Act (CFEPA), but only under specific provisions—namely retaliation and aiding-and-abetting, not for direct discriminatory acts.
Statutory scope
- Sections 46a-60(b)(1) (formerly (a)(1), "employer, by himself or his agent") of CFEPA specifies liability for employers, not "any person." Connecticut Supreme Court precedent makes clear that these subsections address the entity only—not individual employees, supervisors, or managers. See Perodeau v. City of Hartford, 259 Conn. 729 (2002).
- In contrast, sections 46a-60(b)(4) (retaliation) and (b)(5) (aiding and abetting) apply to "any person," explicitly reaching individuals regardless of status as an employer. Thus, supervisors and even rank-and-file employees can be personally liable if they retaliate against a person for engaging in protected activity or knowingly aid or abet a statutory violation.
Key case law
- In Miner v. Town of Cheshire, federal district court analyzed CFEPA and held that individual liability is available for retaliation and aiding-and-abetting, but not for direct discrimination or harassment. See Miner v. Town of Cheshire, No. 3:01CV01709 (D. Conn. Sept. 29, 2003). Connecticut appellate courts have not ruled directly on the issue, but the distinction drawn in Miner has been widely adopted by Connecticut trial and federal courts.
- Perodeau (Conn. 2002) clarifies that there is no individual liability under § 46a-60(b)(1) for workplace discrimination claims (disparate treatment or hostile work environment), except in the retaliation and aiding-and-abetting contexts.
Practical implications
- An individual supervisor or manager can be held personally liable under CFEPA if found to have retaliated against an employee or aided and abetted discriminatory conduct, as defined under § 46a-60(b)(4) and (b)(5).
- For core discrimination claims—such as hiring, firing, or harassment based on a protected class—liability rests solely with the employer entity.
- This structure closely mirrors federal jurisprudence under Title VII, where individual liability is also limited but retaliation/aiding-and-abetting may ensnare individuals in certain circumstances.
Source: Perodeau v. City of Hartford, 259 Conn. 729 (2002) Source: Miner v. Town of Cheshire, No. 3:01CV01709 (D. Conn. Sept. 29, 2003) Source: Conn. Gen. Stat. § 46a-60
CFEPA remedies and damages — CHRO and Superior Court (with federal Title VII comparison)
Connecticut’s Fair Employment Practices Act (CFEPA) provides different remedies depending on whether the complaint is adjudicated administratively by the Connecticut Commission on Human Rights and Opportunities (CHRO) or proceeds to Connecticut Superior Court after a release of jurisdiction (ROJ). Several of these remedies differ significantly from those available under federal law, particularly Title VII of the Civil Rights Act.
Remedies at the CHRO administrative level: Under Conn. Gen. Stat. § 46a-86, when the CHRO finds discrimination, it may order cease-and-desist relief, hiring or reinstatement, back pay (minus interim earnings), restoration of benefits or seniority, actual costs, and reasonable attorney’s fees (Public Act 19-16 clarified attorney's fees and explicitly permits compensatory damages for emotional distress at the administrative level). The CHRO is expressly authorized to award compensatory damages—including for emotional distress—under § 46a-86(c), but may not award punitive damages. These limits are confirmed by statute and agency practice; the agency’s relief is make-whole, focusing on economic loss, pain and suffering, and proven out-of-pocket expenses. Source: Conn. Gen. Stat. § 46a-86 Source: 2019 Conn. Pub. Act No. 19-16
Remedies in Connecticut Superior Court (after CHRO release): After a complainant receives a release of jurisdiction and files in Superior Court under § 46a-100 et seq., the range of available relief is governed by § 46a-104, which grants courts the power to award "such legal and equitable relief which it deems appropriate," including reinstatement, back pay, front pay, attorney's fees and costs, and injunctive relief.
- Punitive damages are NOT available in Superior Court under CFEPA, as the Connecticut Supreme Court held in Tomick v. United Parcel Service, Inc., 324 Conn. 470 (2016): the statute does not authorize punitive damages in employment discrimination cases.
- Compensatory (emotional-distress) damages: The statute does not explicitly authorize emotional-distress damages in Superior Court CFEPA cases. While some lower courts have awarded them, the Connecticut Supreme Court in Tomick noted that it had not decided this issue, and as of July 2026, it remains unsettled and the subject of ongoing trial-level division.
- Attorney’s fees and costs: Reasonable attorney's fees and costs may be awarded under § 46a-104.
- No statutory cap: There is no statutory cap on damages under CFEPA, but the scope of recoverable compensatory damages (particularly emotional distress) in court remains legally unsettled.
Federal Title VII comparison:
- Title VII allows successful claimants reinstatement or hiring with or without back pay, front pay if reinstatement isn’t possible, and other equitable relief (42 U.S.C. § 2000e-5(g)).
- Compensatory damages (including emotional distress) and punitive damages (where the employer acted with malice or reckless indifference) are available, but together are capped at $50,000–$300,000 depending on employer size (42 U.S.C. § 1981a(b)(3)). Attorney’s fees are also recoverable (not subject to the cap).
Summary Table: | Forum | Back Pay | Front Pay | Emotional Distress | Punitive | Attorney's Fees | Cap | |---------------------|---------|-----------|-------------------|-----------|----------------|-------------| | CHRO (CFEPA) | Yes | No | Yes | No | Yes | None | | Superior Court | Yes | Yes | Unsettled† | No | Yes | None | | Title VII (Federal) | Yes | Yes | Yes | Yes | Yes | $50–300k* |
Front pay is generally not available at the CHRO; †Emotional distress available in Superior Court is unsettled; *Title VII cap applies to total compensatory and punitive damages combined, not back/front pay or fees.
Takeaway for practitioners: CFEPA and Title VII both aim to make victims whole—back pay, reinstatement, front pay, and attorney’s fees are available under both—but CFEPA does not permit punitive damages in any forum, and the question of emotional distress damages in court is still an open one.
Source: Conn. Gen. Stat. § 46a-86 Source: 2019 Conn. Pub. Act No. 19-16 Source: Conn. Gen. Stat. § 46a-104 Source: Tomick v. United Parcel Service, Inc., 324 Conn. 470 (2016) Source: 42 U.S.C. § 1981a(b)(3)
Transition filing deadlines for CHRO discrimination complaints (2019–2021)
Connecticut’s filing deadlines for discrimination complaints with the Commission on Human Rights and Opportunities (CHRO) shifted during the 2019–2021 transition period. The deadlines depended on the date of the alleged discriminatory act and the type of claim.
Pre-transition deadlines (before October 1, 2019):
- For most discrimination claims, the CHRO complaint had to be filed within 180 days of the alleged act under Conn. Gen. Stat. § 46a-82(f).
- For complaints of employment discrimination under § 46a-80(a) (unfair discrimination in state licensing or employment based on prior conviction of a crime), the law required filing within 30 days.
Transitional extension (October 1, 2019 – September 30, 2021):
- For discriminatory acts under §§ 46a-60, 46a-70 through 46a-78, 46a-80, or 46a-81c occurring on or after October 1, 2019 but before October 1, 2021, the filing deadline was temporarily extended to 300 days by Public Act 19-16. This extension aligned Connecticut’s deadline with the federal EEOC deadline for cross-filed claims.
Permanent rule (on or after October 1, 2021):
- The 300-day deadline for filing CHRO complaints became permanent for all acts occurring on or after October 1, 2021, as codified by Public Act 21-109 and reflected in Conn. Gen. Stat. § 46a-82(f).
Summary Table:
- Acts before October 1, 2019: 180 days (or 30 days for § 46a-80(a)).
- Acts between October 1, 2019 and September 30, 2021: 300 days (for claims under specific statutes).
- Acts on/after October 1, 2021: 300 days (all covered claims).
Source: Conn. Gen. Stat. § 46a-82(f)
Note: Only the statutory URL has changed; there is no material change to the underlying rule as of June 2024. Previous URL is now dead and has been replaced with the current official version.
Administrative exhaustion requirement under Connecticut’s CFEPA
Administrative exhaustion—the requirement to first pursue a remedy with an administrative agency before going to court—is a strict prerequisite for employment discrimination claims under the Connecticut Fair Employment Practices Act (CFEPA). Under Conn. Gen. Stat. § 46a-100, a complainant alleging a discriminatory employment practice must first file a complaint with the Connecticut Commission on Human Rights and Opportunities (CHRO). Only after obtaining a release of jurisdiction (“ROJ”) from the CHRO may the complainant bring a civil action in Superior Court. Suits filed directly, without CHRO exhaustion and a release, are subject to dismissal (see § 46a-101). This rule aligns Connecticut’s CFEPA with the federal exhaustion requirement found in Title VII cases, albeit with some state-specific mechanics.
The process in detail:
- The complainant must timely file with the CHRO—usually within 300 days of the alleged act (see the "CHRO complaint filing deadline" section).
- The CHRO processes the complaint through intake, review, and formal investigation.
- At several points—a failed mediation, at least 180 days without a determination, or after a case assessment—the complainant can request an ROJ from the CHRO (Conn. Gen. Stat. § 46a-101(b)).
- Once the ROJ is granted, the complainant has 90 days to file suit in Superior Court (§ 46a-101(e)).
Narrow exceptions: State law allows direct-court filing only in limited, non-employment contexts (for example, some credit discrimination claims under § 46a-98 can be filed in court without exhaustion). For employment discrimination under CFEPA, there is no general exception to administrative exhaustion as of June 2026.
Summary: In Connecticut, administrative exhaustion via the CHRO is required for nearly all CFEPA employment discrimination lawsuits. The release of jurisdiction is the necessary ticket to court—filing directly without one is fatal to the claim.
Statutory URLs updated June 2026: The official online publication of Connecticut statutes has changed. Section links now point to the current Chapter 814c landing page, which contains §§ 46a-100 and 46a-101. There is no substantive amendment to these statutes as of this review; only the URLs have changed.
Source: Conn. Gen. Stat. § 46a-100 Source: Conn. Gen. Stat. § 46a-101
Remedies under CFEPA — CHRO vs. Superior Court (compensatory, punitive, attorney's fees)
The remedies for a successful Connecticut Fair Employment Practices Act (CFEPA) claim differ depending on whether the case stays at the administrative level with the Connecticut Commission on Human Rights and Opportunities (CHRO) or proceeds to court after a release of jurisdiction (ROJ).
CHRO-level (administrative) remedies: The CHRO may order reinstatement or hiring, back pay, and other equitable relief to redress discrimination (including policy changes or training). Pursuant to Conn. Gen. Stat. § 46a-86 and case law (e.g., Bridgeport Hospital v. CHRO), the CHRO may not award compensatory damages (such as for emotional distress or pain and suffering), punitive damages, or attorney’s fees. CHRO authority is limited by statute to make-whole remedies: economic damages such as lost wages and reinstatement are allowed, but tort-style monetary damages and fee awards are not. Source: Conn. Gen. Stat. § 46a-86 Source: Bridgeport Hospital v. Commission on Human Rights and Opportunities, 232 Conn. 91 (1995)
Superior Court (after ROJ): After obtaining a release of jurisdiction from the CHRO, a complainant may file suit in Connecticut Superior Court under Conn. Gen. Stat. § 46a-100 et seq. The court may award legal and equitable relief, which includes reinstatement, back pay, front pay, injunctive relief, reasonable attorney’s fees and costs, and, as of October 1, 2019, punitive damages. This express statutory authorization for punitive damages was added by Public Act 19-16 (§ 15), superseding the Connecticut Supreme Court’s earlier holding in Tomick v. United Parcel Service, Inc., 324 Conn. 470 (2016), which held punitive damages were unavailable under the prior statutory language.
- Punitive damages: Expressly permitted under § 46a-104 since 2019. Tomick v. UPS is superseded as to this point.
- Compensatory (emotional distress) damages: The availability of compensatory damages—especially for emotional distress—in court after CHRO release remains unsettled. Tomick did not resolve this issue. Connecticut trial courts and federal courts have varied in their interpretation, with no definitive Connecticut Supreme Court holding as of July 2024.
- Attorney’s fees: Superior Court may award reasonable attorney’s fees and costs to prevailing complainants under § 46a-104.
Summary Table | Forum | Remedies Available | |-----------------------|----------------------------------------------------------| | CHRO (admin) | Equitable remedies (hiring/reinstatement), back pay; no punitive, compensatory, or attorney’s fees. | | Superior Court | Broad legal/equitable remedies, back/front pay, attorney’s fees/costs, and punitive damages (since 2019); emotional distress damages unsettled. |
Source: Conn. Gen. Stat. § 46a-86 Source: Conn. Gen. Stat. § 46a-104 Source: Bridgeport Hospital v. Commission on Human Rights and Opportunities, 232 Conn. 91 (1995)
EEOC–CHRO dual-filing (work-sharing agreement)
Connecticut and the federal Equal Employment Opportunity Commission (EEOC) have a work-sharing agreement that enables "dual-filing" of workplace discrimination complaints. When a complainant files a charge with either the Connecticut Commission on Human Rights and Opportunities (CHRO)—Connecticut's Fair Employment Practices Agency (FEPA)—or the EEOC, and the allegation is covered by both state and federal law, the receiving agency automatically cross-files the complaint with the other. No separate filing or affirmative election is required by the complainant—dual-filing is mandatory and automatic under the agreement.
How the process works:
- Filing through CHRO: When you file a charge with CHRO on a basis also covered by federal law (such as Title VII, the ADA, or ADEA), CHRO forwards the complaint to the EEOC, preserving federal claims and enabling the possibility of federal remedies if the case proceeds that way.
- Filing through EEOC: When you file directly with the EEOC about conduct occurring in Connecticut, EEOC will transmit your charge to CHRO as well. The complaint is thus preserved as a state claim, even when started federally. In practice, the agency that receives the complaint usually processes and investigates it, and only one agency typically conducts the investigation.
Preservation of claims: Filing with either agency (CHRO or EEOC) within the applicable 300-day period preserves both state and federal discrimination claims. This is true even if the complainant does not specifically request dual-filing during intake—the agencies are required by their work-sharing agreement to cross-file any covered charge.
Summary:
- Cross-filing is automatic; the complainant does not need to act beyond the original filing.
- Filing with EEOC instead of CHRO can still preserve Connecticut state-law claims (and vice versa) if the substantive allegations are covered by both statutes.
- Only one agency will process the case, but dual agency rights are preserved.
Source: EEOC — FEPAs and Dual Filing
Note: The official Connecticut General Assembly report cited in earlier versions (“CHRO Final Report January 6, 2017”) could not be relinked due to its removal or relocation on cga.ct.gov as of this review. No material change to the underlying dual-filing or work-sharing framework has occurred as of June 2024.
CFEPA exemptions and exclusions — religious organizations, employment status, and other carve-outs
The Connecticut Fair Employment Practices Act (CFEPA) provides broad antidiscrimination coverage for employees, but there are several explicit exclusions and statutory carve-outs that practitioners should note.
Religious organizations: Certain provisions of CFEPA do not apply to religious corporations, associations, or societies. For example, Conn. Gen. Stat. § 46a-81p states that the section on sexual orientation-based employment discrimination does not apply to "a religious corporation, association, educational institution or society with respect to the employment of individuals of a particular religion to perform work connected with the carrying on by such corporation, association, educational institution or society of its activities." This means religious entities can give employment preference based on religion and are exempt from sexual orientation anti-discrimination rules for roles connected to religious functions. More generally, § 46a-56 allows religious organizations to limit employment or give preference to persons of the same religion in connection with religious activities.
Employee definition — exclusions: CFEPA defines "employee" at § 46a-51(9) to exclude "any individual employed by such individual's parents, spouse or child." Additionally, CFEPA applies only in the context of an employer-employee relationship as defined by statute. The term "employee" is not defined to include independent contractors, and there is no express inclusion of volunteers—coverage turns on whether a worker qualifies as an "employee" under the statute.
Elected and appointed officials: Effective October 1, 2022, Public Act 22-82 amended the statute to include elected or appointed officials as "employees" for purposes of CFEPA protections.
No small-employer exemption: Unlike the federal Title VII, which exempts employers with fewer than 15 employees, CFEPA defines "employer" at § 46a-51(10) as any person with one or more employees. There are no thresholds or protected-class-specific exclusions removing small employers from coverage.
In summary, CFEPA's principal exclusions are (1) religious preference exceptions for religious organizations and (2) the statutory definition of "employee," which does not extend to family employees, independent contractors, or, on the face of the statute, volunteers.
Source: Conn. Gen. Stat. § 46a-51(9), (10) Source: Conn. Gen. Stat. § 46a-56(a) Source: Conn. Gen. Stat. § 46a-81p Source: 2022 Conn. Pub. Act No. 22-82
Connecticut hostile work environment standard under CFEPA
Connecticut recognizes hostile-work-environment claims under the Connecticut Fair Employment Practices Act (CFEPA, Conn. Gen. Stat. § 46a-51 et seq.), and courts apply a legal standard paralleling Title VII of the Civil Rights Act of 1964.
Legal standard:
- To prevail, a complainant must show the workplace was "permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment." This language and standard have been adopted explicitly by the Connecticut Supreme Court. See Brittell v. Department of Correction, 247 Conn. 148, 166–67 (1998).
- Conduct must be both objectively hostile or abusive to a reasonable person and subjectively perceived as hostile by the complainant. Connecticut courts follow this two-prong test, consistent with Supreme Court and Second Circuit precedent interpreting federal law under Title VII.
- Factors the court weighs include frequency and severity of the conduct, whether it is physically threatening or humiliating or merely offensive, and whether it unreasonably interferes with an employee’s work performance. Isolated or sporadic incidents, unless extremely severe, are usually insufficient.
Vicarious liability—who is a "supervisor" under CFEPA?
- In O’Reggio v. Commission on Human Rights and Opportunities (2024), the Connecticut Supreme Court adopted the U.S. Supreme Court's definition of "supervisor" from Vance v. Ball State University for CFEPA hostile-work-environment claims. Only employees empowered to take tangible employment actions—like hiring, firing, disciplining, or making significant changes in benefits—are "supervisors" for vicarious employer liability. If the harasser is a supervisor, the employer can be vicariously liable, subject to an affirmative defense; if a coworker, employer liability turns on negligence.
Summary:
- CFEPA recognizes hostile-work-environment claims and employs a severe-or-pervasive standard, objective/subjective offensiveness, and the "supervisor" definition for vicarious liability as articulated in O’Reggio, in line with federal Title VII doctrine.
Source: Brittell v. Department of Correction, 247 Conn. 148 (1998) Source: O’Reggio v. Comm'n on Human Rights and Opportunities (Conn. 2024)