Conn. Gen. Stat. » Title 46a — HUMAN RIGHTS · Chapter 814c — Human Rights and Opportunities
Connecticut General Statutes

Conn. Gen. Stat. § 46a-104 (2026)

Civil action for discriminatory practice: Relief

✓ current as of May 2026
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The court may grant a complainant in an action brought in accordance with section 46a-100 such legal and equitable relief which it deems appropriate including, but not limited to, temporary or permanent injunctive relief, punitive damages, attorney's fees and court costs. The amount of attorney's fees allowed shall not be contingent upon the amount of damages requested by or awarded to the complainant.

(P.A. 91-331, S. 5; P.A. 11-237, S. 15; P.A. 19-16, S. 10.)

History: P.A. 11-237 added provision re amount of attorney's fees allowed; P.A. 19-16 added “punitive damages,”.

Cited. 232 C. 91. In light of Ames v. Commissioner of Motor Vehicles, 267 Conn. 524, and a close reading of text of section in relation to other related human rights statutes, section does not authorize an award of punitive damages in employment discrimination cases. 324 C. 470.

Cited. 44 CA 446. Court did not abuse its discretion by awarding plaintiff attorney's fees because jury found defendant created hostile work environment in violation of Sec. 46a-60 and awarded punitive damages. 117 CA 680. The legislature did not, either expressly or by force of a necessary implication, statutorily waive the state's sovereign immunity from liability for punitive damages under the fair employment practices act. 118 CA 65. Section does not explicitly authorize award of punitive damages, therefore plaintiff is not entitled to such relief under section; despite use of the phrase “including, but not limited to” to modify the phrase “legal and equitable relief”, section already explicitly authorizes award of attorney's fees and litigation costs, and awarding punitive damages would provide plaintiff with double recovery and alter the settled common-law rule limiting punitive damages to a single recovery of litigation expenses, and there is no clear intent by the legislature to provide multiple recovery of attorney's fees and litigation costs under section. 157 CA 312; judgment affirmed, see 324 C. 470.

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Secs. 46a-105 to 46a-125. Reserved for future use.

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Notes of Decisions
Cited in 23 cases (4 in the last 5 years), 1995–2026 · leading case: Tomick v. United Parcel Serv., Inc., 153 A.3d 615 (Conn. 2016).
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Tomick v. United Parcel Serv., Inc., 153 A.3d 615 (Conn. 2016). · cites it 95× “**472 In this certified appeal, we consider whether General Statutes § 46a-104 1 provides for an award of statutory punitive damages as a remedy for discriminatory practices under the Connecticut Fair Employment Practices Act (act), General Statutes § 46a-51 et seq.”
Jackson v. Water Pollution Control Auth., 900 A.2d 498 (Conn. 2006). · cites it 5× “Resolution of the plaintiffs claim, therefore, hinges on the meaning of the remedy provision of the act, namely, General Statutes § 46a-104, 15 and requires a two step analysis, specifically whether: (1) the plaintiff was entitled to a jury determination of damages on his cause…”
Tomick v. United Parcel Serv., Inc., 43 A.3d 722 (Conn. App. Ct. 2012). · cites it 8× “” 24 General Statutes § 46a-104 provides: “The court may grant a complainant in an action brought in accordance with section 46a-100 such legal and equitable relief which it deems appropriate including, but not limited to, temporary or permanent injunctive relief, attorney’s…”
Perez v. D & L Tractor Trailer Sch., 981 A.2d 497 (Conn. App. Ct. 2009). · cites it 6× “Although unfamiliar with the trial work of the plaintiffs counsel, the expert knew of counsel’s work several years earlier when he worked in a defense firm.”
Ware v. State, 983 A.2d 853 (Conn. App. Ct. 2009). · cites it 8× “Ill The defendant’s final claim is that the court improperly determined that sovereign immunity did not bar the plaintiffs claim for punitive damages pursuant to General Statutes § 46a-104. 13 We agree. We again note that the question of whether § 46a-104 either expressly or by…”
Bridgeport Hosp. v. Comm'n on Human Rights & Opportunities, 653 A.2d 782 (Conn. 1995). · cites it 3× “” 19 CHRO points to General Statutes § 46a-104 as an example of a statute that reflects the legislature’s concern that employees who have suffered discrimination receive full compensation.”
Thibodeau v. Design Grp. One Architects, LLC, 802 A.2d 731 (Conn. 2002). · cites it 2× “” General Statutes § 46a-104. As originally enacted, the act applied only to employers with five or more employees.”
Davis v. Manchester Health Ctr., Inc., 867 A.2d 876 (Conn. App. Ct. 2005). · cites it 8× “The defendant also claims that if the plaintiff is not entitled to judgment on her wrongful termination claim, she is not entitled to an award of attorney’s fees as provided for in General Statutes § 46a-104. 2 We affirm the judgment of the trial court.”
Comm'n on Human Rights & Opportunities v. Brookstone Court, LLC, 945 A.2d 548 (Conn. App. Ct. 2008). · cites it 7× “The court examined General Statutes § 46a-104* ****** 8 and 42 U.”
Thames Talent, Ltd. v. Comm'n On Human Rights & Opportunities, 827 A.2d 659 (Conn. 2003). · cites it 2× “In particular, Thames Talent claims that, because the Superior Court has the authority in such a civil action to grant “such legal and equitable relief which it deems appropriate”; General Statutes § 46a-104; the legislature intended to limit the relief available under § 46a-86…”
Tammie Ackelson v. Manley Toy Direct, L.L.C. & Toy Network, L.L.C. v. Manley Toy Direct, L.L.C.. & Toy Network, L.L.C., 832 N.W.2d 678 (Iowa 2013). “§ 414481(G) (2011); Conn. Gen.Stat. Ann. § 46a-104 (West 2009); D.”
Shaw v. Greenwich Anesthesiology Assocs., P.C., 200 F. Supp. 2d 110 (D. Conn. 2002). · cites it 4× “PLAINTIFF’S MOTIONS FOR ATTORNEYS’ FEES Plaintiff moves for an amended award of attorneys’ fees in the amount of $219,867.”
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