In the case Thames Talent, Ltd. v. Commission on Human Rights & Opportunities, 265 Conn. 127 (2003), a female employee filed a complaint under Conn. Gen. Stat. § 46a-60(a)(4) and (8), alleging sexual harassment and retaliatory discharge after objecting to her employer’s offensive conduct. A hearing officer found that the employer created a hostile work environment and unlawfully terminated her employment. The officer awarded back pay and interest but declined reinstatement due to the deteriorated employment relationship.
The employer appealed, arguing that back pay could not be awarded without reinstatement. The Connecticut Supreme Court rejected that argument and affirmed the award, holding that Conn. Gen. Stat. § 46a-86(b) authorizes back pay independently of reinstatement when necessary to make a complainant whole. The Court also upheld the order requiring repayment of unemployment benefits to the state and confirmed that both pre-judgment and post-judgment interest are appropriate remedies under § 46a-86(b).