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Polauf Law LLC Stephen Polauf · Attorney at Law

Fees & Services

Dispute Representation / Litigation

Employment and business dispute litigation in Connecticut Superior Court.

Employment Litigation

For employers, a single employment case can expose the company to back pay, front pay, compensatory damages, reinstatement, injunctive relief, and attorney's fees. For employees, litigation is the only avenue to recover what they lost: back pay, front pay, compensatory damages, and attorney's fees.

Connecticut employment lawsuits arise under several statutes. The Connecticut Fair Employment Practices Act, CGS §§ 46a-51 et seq., prohibits discrimination, harassment, and retaliation based on protected characteristics and requires exhaustion through the CHRO before a plaintiff may file in Superior Court. Federal claims arise under Title VII, the ADEA, ADA, and FMLA. ERISA, 29 U.S.C. § 1001 et seq., governs employee benefit plan disputes. Connecticut common law covers wrongful termination in violation of public policy and breach of employment contract.

An employee who prevails on a CFEPA claim may recover back pay, front pay, attorney's fees, and equitable relief under CGS § 46a-104, though punitive damages are not available under state law following Tomick v. UPS. Under Title VII and § 1981, punitive damages are available where the employer acted with malice or reckless indifference to the employee's federally protected rights, subject to caps based on employer size.

An employment discrimination case requires a plaintiff to establish a prima facie case (adverse employment action, protected class membership, qualification for the position, and circumstances giving rise to an inference of discrimination), shifting the burden to the employer to articulate a legitimate, nondiscriminatory reason, which the plaintiff must then show is pretextual. That framework governs at summary judgment, and summary judgment in employment cases is the dispositive moment.

My Litigation Practice

My practice is focused on employment and business disputes. I have litigated in Connecticut Superior Court, secured summary judgment and dismissal for employer clients on wage and hour, ERISA, ADA, and employment discrimination claims, and defeated class certification in a collective action. I have also represented employees and secured five-figure settlements in my first year of solo practice, and I have moved for resolution in business disputes to secure judgment.

I have handled civil litigation at all stages: pleadings, discovery, dispositive motions, and settlement. Prior to solo practice I worked at firms where teams of associates handled discovery and document review.

Discovery in employment litigation deserves attention. The scope of what an opposing party demands, and what you must produce, are not the same thing. Employment cases generate discovery requests that are overbroad, disproportionate, and designed to impose cost rather than obtain relevant information. Handling discovery means defining your own obligations clearly, pushing back on requests that exceed what the rules require, and keeping the process focused. That approach saves clients money and time. I developed it while managing discovery demands in cases with large document volumes and small teams. Controlling discovery costs resolves cases before trial.

For Employers

By the time a complaint is filed and discovery opens, the employer's documentary record is fixed. I advise employers on litigation strategy from the outset, draft dispositive motions aimed at resolution before trial, and manage discovery to prevent exposure. The goal is resolution before trial (through dismissal, summary judgment, or negotiated settlement), with trial when settlement or dismissal is not possible.

For Employees

If you have lost your job, been passed over, or been subjected to a hostile workplace because of a protected characteristic, CFEPA claims must be filed with the CHRO within 300 days of the discriminatory act under CGS § 46a-82. Missing that deadline forecloses viable claims. I assess cases, advise on forum and strategy, and pursue back pay, front pay, compensatory damages, and attorney's fees.

Claim Filing Deadline: 300 Days

CFEPA claims must be filed with the CHRO within 300 days of the discriminatory act under CGS § 46a-82. Missing that deadline forecloses otherwise viable claims entirely.

Scope of Service

  • Employer defense in employment discrimination, harassment, and retaliation claims (CFEPA, Title VII, ADA, ADEA, FMLA, ERISA)
  • Motions to dismiss, summary judgment, and appellate practice
  • Employee representation in discrimination, retaliation, and wrongful termination matters
  • Severance agreement review and negotiation
  • Discovery strategy, objections, and proportionality disputes
  • Business and contract dispute litigation
  • CHRO proceedings through right-to-sue and Superior Court filing