Since 2020, a lot of people quietly assumed one thing: if you can do a job on a laptop, then remote work must be a “reasonable accommodation” forever. A recent decision from the Connecticut Appellate Court brought everyone back down to earth. The court ruled that, under disability law, employers don’t have to agree to full-time remote work when in-person duties are truly essential to the jobeven if the employee worked from home during the pandemic.

In other words: Zoom is great, but it’s not a legal magic wand. Let’s walk through what the court actually said, what this means for employers and employees, and how to handle remote-work accommodation requests without stepping into a legal minefield.

The Case Behind the Headline

Who was involved?

The case that sparked all the headlines is Castelino v. Whitman, Breed, Abbott & Morgan, LLC, a 2025 decision by the Connecticut Appellate Court. The plaintiff was a legal/administrative assistant at a law firm in Greenwich, Connecticut. She had underlying medical conditions, including diabetes and asthma, and became worried when she learned that their office building housed a COVID-19 testing facility in 2020.

Out of concern for her health, she requested to work exclusively from home. The firm said no to full-time remote work, but did allow a mix of remote work and in-office time. Eventually, after performance concerns, her employment ended and she sued, claiming disability discrimination and failure to reasonably accommodate.

What did the Connecticut court actually decide?

The Appellate Court sided with the employer. It concluded that:

• Her job required “some measure of in-person work”, such as maintaining physical files, obtaining ink signatures, handling notarizations, and accepting documents from clients.
• Those in-person tasks were essential functions of her positionnot optional add-ons.
• Because full-time remote work would completely eliminate those in-person duties, her request was not a reasonable accommodation as a matter of law.

That last phrase is crucial. The court didn’t just say “we don’t like remote work.” It said that if an accommodation would wipe out an essential function, it simply cannot be considered reasonable under Connecticut law and under the framework used in Americans with Disabilities Act (ADA) cases.

Why this ruling matters

This was widely described by employment law firms and business groups as a first-of-its-kind decision in Connecticut. It gives employers clearer support for requiring in-person work when that’s truly necessary to the job and confirms that:

• Employers do not have to grant full-time remote work if essential functions must be done on site.
• Courts will give considerable deference to an employer’s judgment about what counts as essentialespecially when it’s backed by written job descriptions and consistent practice.

So, remote work might be convenient, efficient, and great for your dog. But that doesn’t automatically make it a legally required accommodation.

How the Law Looks at Remote Work as an Accommodation

The ADA and “essential functions”

Under the Americans with Disabilities Act (ADA) and similar state laws, employers must provide reasonable accommodations that enable qualified employees with disabilities to perform the essential functions of their jobs, unless doing so creates an undue hardship. Courts look at factors like:

• Written job descriptions.
• How much time is actually spent on particular tasks.
• What the employer says is essentialand how the job is performed in reality.
• Whether others in similar roles also perform those duties.

In the Connecticut case, both testimony and job duties showed that in-person workhandling physical documents, notarizations, client drop-offswas genuinely part of the job, not a rare exception. That made in-office presence an essential function, not a negotiable perk.

Remote work: more common, still not automatic

After the pandemic, many courts have been more open to telework as a potential reasonable accommodation. But legal commentators repeatedly emphasize that telework is not automatically reasonable, and each case depends on whether the employee can still perform all essential functions from home.

Federal courts in other parts of the country have also upheld employers that declined full-time telework when essential functions clearly required in-person presencefor example, where employees needed to interact with students, handle physical evidence, or perform hands-on tasks. The emerging pattern is consistent: telework can be reasonable, but not when it guts the heart of the job.

Key Lessons for Employers

1. Clearly define essential functions (and keep them updated)

The Connecticut decision repeatedly highlights how important it was that in-office work was documented and well understood as part of the role. Employers should:

• Maintain accurate, detailed job descriptions that spell out any required in-person duties (e.g., handling physical files, in-person client meetings, on-site inspections).
• Ensure managers actually follow those descriptions in practicebecause courts also look at what happens in real life, not just on paper.
• Update job descriptions periodically to reflect post-pandemic changes, hybrid models, or new technology.

Think of your job description as the “user manual” for a court trying to understand whether an employee’s requested accommodation makes sense.

2. Don’t rely on blanket “no remote work” rules

The ruling does not say that employers can deny all remote-work accommodations. Instead, it says that full-time remote work is not required when it would eliminate essential functions. If a job can be done entirely online, or if in-person tasks are minor or easily reassigned, telework might still be a reasonable accommodation.

That’s why many law-firm alerts stress the importance of a case-by-case analysis. A total, across-the-board ban on telework accommodations can still lead to trouble.

3. Use the interactive process (and document it)

Employers are expected to engage in a good-faith interactive process when an employee requests an accommodation:

• Clarify what limitations the employee has and how those affect essential job duties.
• Explore alternatives if full-time remote work isn’t feasible: staggered hours, modified workspace, masks, air filtration, hybrid schedules, or reassignment to a more remote-friendly role.
• Document the conversations and options discussed, even if you ultimately can’t agree on the employee’s preferred solution.

Courts tend to look more favorably on employers that can show they treated the request seriously, even when they ultimately said no.

4. Train managers on the difference between “preference” and “accommodation”

Since the pandemic, a lot of remote-work conversations start with “I just work better from home.” That’s a preference, not necessarily a disability-related accommodation request. Managers should be trained to:

• Recognize when a request might trigger ADA or state disability laws (e.g., when an employee mentions a medical condition or treatment).
• Loop in HR or legal counsel quickly instead of making off-the-cuff promises or denials.
• Avoid emails that casually label jobs as “fully remote” when that’s not 100% true.

A sloppy Slack message today can become Exhibit A in court tomorrow.

What Employees and Job Seekers Should Know

1. Remote work is not a guaranteed righteven with a disability

The Connecticut decision is a reminder that even with a legitimate disability, you are not automatically entitled to work from home full-time. The legal test is whether your requested accommodation allows you to perform all essential job functions, not whether it makes you more comfortable or matches your ideal lifestyle.

That might sound harsh, but it’s how courts across the country increasingly frame these disputes.

2. But you still have important rights

None of this means “no remote work for anyone, ever.” If your job is largely computer-based and does not require in-person contact, remote work or hybrid work might be a very reasonable accommodation. In fact, courts and the EEOC have recognized that telework can be appropriate where it doesn’t remove essential duties and where the employer has successfully used remote arrangements before.

If you’re seeking remote work as an accommodation:

• Be prepared to explain how you’ll perform each essential function from home.
• Be open to alternativeslike hybrid work or modified dutiesif the employer can’t agree to 100% telework.
• Keep written records of your requests, doctor notes (where appropriate), and the employer’s responses.

3. Don’t confuse pandemic flexibility with permanent legal standards

Many employees reasonably feel that “we did everything from home in 2020, so it must be reasonable forever.” Courts and commentators have consistently pushed back on that logic. Temporary emergency arrangementsmade in the middle of a pandemicdon’t automatically redefine what’s essential long-term. Employers can, and often do, re-evaluate job requirements as they bring people back to the office.

The Connecticut ruling reflects that reality: past remote work doesn’t automatically force an employer to approve full-time telework as a permanent accommodation.

How This Fits Into the Bigger Remote-Work Debate

Connecticut isn’t alone. Courts in other circuits have held that:

• Telecommuting is not always a reasonable accommodation where in-person collaboration, supervision, or on-site presence is central to the job.
• Requests for temporary but total telework can be rejected when essential functions require being there in person, even if the employee expects to recover later.

At the same time, remote work is still a major part of the modern workplace, and many organizations continue to offer it as a benefit, even when not legally required. Surveys show a growing push for hybrid models, with employers balancing in-office collaboration against competition for talent and employee expectations shaped by the pandemic years.

Bottom line: the law is moving toward a pragmatic middle ground. Telework is sometimes a reasonable accommodation, but courts are making it very clear that it is not always</strong reasonableespecially when it erases core responsibilities that must happen face to face.

Real-World Experiences and Practical Scenarios (Extra Insights)

To make this less abstract, imagine a few real-world scenarios that echo what the Connecticut court was wrestling with.

A Connecticut law firm rewrites its job descriptions

After the Castelino decision, picture a mid-sized law firm in Hartford sitting down with HR, partners, and office managers. They pull out every job description for legal assistants, paralegals, and closing coordinators and start highlighting phrases like “must be able to notarize documents” or “handle original closing files.”

Before the pandemic, nobody thought twice about those tasks being in personthey were just “how the job works.” Now, the firm realizes it needs to say the quiet part out loud: in-office presence is essential for certain roles. They update descriptions to spell this out, train managers to reinforce it during onboarding, and make sure offer letters match the reality.

A year later, when an employee asks for permanent full-time remote work as an accommodation, the firm is in a much stronger position to explain why that particular request isn’t reasonablewhile still exploring hybrid or other options.

An HR manager handles a tricky remote-work request

Now imagine an HR director at a Connecticut tech company. Most of the engineers are already hybrid, and many could theoretically code from anywhere with Wi-Fi and a decent coffee supply. One engineer with an autoimmune condition asks to go fully remote, citing fears about commuting and shared office air.

The HR director, who has been following the Castelino decision, doesn’t just reply, “Nope, court says remote work isn’t reasonable.” Instead, she does the legally smartand humanthing:

• She confirms the health-related nature of the request and asks what specific limitations the employee faces.
• She reviews the engineer’s essential functions: coding, code reviews, stand-ups, occasional on-site meetings with hardware teams.
• She talks with the manager and discovers that in-person work is important a few days a month, but not every week.

The result? They agree on a hybrid accommodation: mostly remote, with pre-scheduled in-office days for critical collaboration and access to specialized equipment. It’s not 100% remote, but it meaningfully reduces the employee’s risk and works operationally. That’s exactly the kind of nuanced, case-by-case compromise courts expect to see.

An employee learns to frame their request more effectively

Consider an employee with anxiety and a history of panic attacks triggered by crowded transit and open-plan offices. Before learning about the Connecticut ruling, they might simply email their boss: “I want to work from home full-time. It just works better for me.”

After reading about the case, they approach things differently:

• They talk with their clinician and obtain documentation explaining how commuting and certain environments exacerbate their condition.
• They review their job duties and identify which ones truly require in-person presence (monthly client demos, for example), versus what can realistically be done remotely.
• They propose a structured plan: remote work most days, with scheduled, predictable in-office visits and use of quieter spaces when on site.

Suddenly, the employer has a concrete, well-supported proposal to evaluatenot just a preference. Even if full-time remote work isn’t approved, the employee is more likely to walk away with a meaningful accommodation that respects their health and the employer’s operational needs.

The big picture: balance, not absolutes

The Connecticut Appellate Court didn’t slam the door on remote work. It simply reminded everyone that the law is about reasonableness in context, not wish lists. For employers, that means defining and defending what’s essential. For employees, it means asking not “Can I have my ideal setup?” but “What accommodation lets me do the heart of my job in a safe, sustainable way?”

As the post-pandemic workplace keeps evolving, this decision is one more data point in a larger story: remote work is here to staybut as a flexible tool, not a guaranteed right.

Conclusion

The Connecticut ruling that remote work is not always a reasonable accommodation doesn’t kill remote work. It puts guardrails around it. Employers can usually require in-person work when that’s genuinely part of the job’s core, especially when they’ve documented those expectations. Employees with disabilities still have strong rightsbut those rights focus on enabling them to perform essential duties, not on guaranteeing a particular work location.

If you remember nothing else, remember this: remote work can be a reasonable accommodation, but only when it fits the job. The law, like a good manager, is looking for solutions that are practical, fair, and grounded in how the work actually gets done.

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