WAGE AND HOUR DEMAND LETTER
State of Connecticut
Fair Labor Standards Act and Connecticut Wage Law Claims
[ATTORNEY/FIRM LETTERHEAD]
[Firm Name]
[Address Line 1]
[City, Connecticut ZIP]
Tel: [Phone Number]
Fax: [Fax Number]
[Attorney Email]
[Connecticut Bar Juris Number]
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED
AND VIA EMAIL TO: [recipient_email]
[Date]
[Employer Contact Name]
[Title]
[Company Legal Name]
[Company Address]
[City, State ZIP]
Re: Wage and Hour Violations - [Client Full Name]
Demand for Unpaid Wages Under Connecticut General Statutes and FLSA
CONFIDENTIAL SETTLEMENT COMMUNICATION PURSUANT TO FRE 408 and Conn. Code Evid. Section 4-8
Dear [Mr./Ms./Mx. Last Name]:
This firm represents [Client Full Name] regarding claims for unpaid wages against [Company Legal Name] arising from violations of Connecticut General Statutes Sections 31-58 et seq. (Minimum Wage), Sections 31-71a et seq. (Wage Payment), and the Fair Labor Standards Act ("FLSA"), 29 U.S.C. Section 201 et seq.
I. CONNECTICUT-SPECIFIC LEGAL FRAMEWORK
A. Connecticut Wage and Hour Requirements
Connecticut provides strong employee protections with minimum wages significantly above the federal rate.
Key Requirements:
| Category | Connecticut Requirement | Citation |
|---|---|---|
| Minimum Wage | $16.35/hour (2026) | Conn. Gen. Stat. Section 31-58(i) |
| Overtime | 1.5x after 40 hours/week | Conn. Gen. Stat. Section 31-76c |
| Tipped Minimum | $6.38/hour (bartenders: $8.23) | Conn. Gen. Stat. Section 31-60(b) |
| Pay Frequency | Weekly | Conn. Gen. Stat. Section 31-71b |
| Final Pay (Fired) | Next business day | Conn. Gen. Stat. Section 31-71c(b) |
| Final Pay (Quit) | Next regular payday | Conn. Gen. Stat. Section 31-71c(b) |
| Meal Period | 30 min for 7.5+ hour shifts | Conn. Gen. Stat. Section 31-51ii |
B. Connecticut Minimum Wage
Annual Increases: Connecticut minimum wage is indexed to the Employment Cost Index (ECI), increasing automatically each January 1.
Hotel and Restaurant Employees:
- Higher tipped minimum wage for bartenders: $8.23/hour (2026)
- Other tipped employees: $6.38/hour (2026)
- Tip credit maximum: $9.97/hour (service) or $8.12/hour (bartenders)
C. Connecticut Overtime Requirements
Coverage: Connecticut overtime law covers most employers regardless of size (broader than FLSA).
| Requirement | Standard |
|---|---|
| Threshold | 40 hours per week |
| Rate | 1.5x regular rate |
| Exemptions | Similar to federal but Connecticut-specific tests |
D. Meal Period Requirements
Conn. Gen. Stat. Section 31-51ii:
| Requirement | Standard |
|---|---|
| Applicability | Employers in manufacturing, mechanical, or mercantile establishments |
| Trigger | Shifts of 7.5 consecutive hours or more |
| Duration | 30 minutes |
| Timing | After first 2 hours and before last 2 hours of shift |
E. Statute of Limitations
| Claim Type | Limitations Period | Citation |
|---|---|---|
| Connecticut wage claims | 2 years | Conn. Gen. Stat. Section 52-596 |
| FLSA (standard) | 2 years | 29 U.S.C. Section 255(a) |
| FLSA (willful) | 3 years | 29 U.S.C. Section 255(a) |
F. Penalties and Remedies
Connecticut Wage Payment (Conn. Gen. Stat. Section 31-72):
| Violation Type | Remedy |
|---|---|
| Unpaid wages | Full amount owed |
| Double damages | 2x unpaid wages for violations |
| Attorney's fees | Mandatory for prevailing employee |
| Costs | Recoverable |
| Civil penalties | Up to $300 per violation |
Note: Connecticut provides automatic double damages; employer must prove good faith to avoid doubling.
G. Enforcement Mechanisms
Administrative:
- Connecticut Department of Labor, Wage and Workplace Standards Division
- File wage complaint (no fee)
- Investigation and hearing process
- Can order payment of wages plus penalties
Private Right of Action:
- Conn. Gen. Stat. Section 31-72: Express private right of action
- Double damages presumed
- Mandatory attorney's fees
- Class actions available
II. INTRODUCTION AND SUMMARY OF CLAIMS
Our client was employed by [Company Short Name] as a [Job Title] from [Start Date] to [End Date / Present] in Connecticut. [Company Short Name] violated Connecticut and federal wage laws by:
[ ] Failing to pay Connecticut minimum wage of $16.35 per hour
[ ] Failing to pay overtime at 1.5 times the regular rate for hours over 40/week
[ ] Misclassifying our client as exempt from overtime
[ ] Misclassifying our client as an independent contractor
[ ] Improperly taking tip credit without meeting requirements
[ ] Failing to provide required meal periods for shifts over 7.5 hours
[ ] Failing to pay weekly as required
[ ] Failing to pay final wages on time upon termination
[ ] Making unlawful deductions from wages
III. FACTUAL BACKGROUND
A. Employment Relationship
| Category | Details |
|---|---|
| Employee Name | [Client Full Name] |
| Job Title(s) | [Title(s)] |
| Dates of Employment | [Start Date] to [End Date / Present] |
| Work Location(s) | [Address(es) in Connecticut] |
| Primary Duties | [Describe job duties] |
| Rate of Pay | $[Amount] per hour |
| Classification | [Exempt / Non-Exempt / Independent Contractor] |
| Pay Frequency | [Weekly / Other - note violation if not weekly] |
B. Hours Worked
Typical Weekly Schedule:
| Day | Hours Worked | Meal Period Provided? |
|---|---|---|
| Monday | [X.X hrs] | [Y/N] |
| Tuesday | [X.X hrs] | [Y/N] |
| Wednesday | [X.X hrs] | [Y/N] |
| Thursday | [X.X hrs] | [Y/N] |
| Friday | [X.X hrs] | [Y/N] |
| Saturday | [X.X hrs] | [Y/N] |
| Sunday | [X.X hrs] | [Y/N] |
| Weekly Total | [X hrs] |
IV. LEGAL ANALYSIS
A. Connecticut Wage Law Violations
1. Minimum Wage (Conn. Gen. Stat. Section 31-58)
Connecticut's minimum wage of $16.35/hour significantly exceeds the federal minimum. [Company Short Name] failed to pay this rate by [describe violation].
2. Overtime (Conn. Gen. Stat. Section 31-76c)
Connecticut requires overtime pay at 1.5x for hours over 40 per week. Our client worked [X] hours per week without proper overtime.
3. Meal Period Violation (Conn. Gen. Stat. Section 31-51ii)
[If applicable:] [Company Short Name] failed to provide required 30-minute meal periods for shifts exceeding 7.5 hours.
4. Final Pay Violation (Conn. Gen. Stat. Section 31-71c)
[If applicable:] Upon [discharge on Date], [Company Short Name] failed to pay all wages by the next business day as required.
B. Double Damages
Under Conn. Gen. Stat. Section 31-72, our client is entitled to double damages. The burden is on [Company Short Name] to prove good faith to avoid doubling, which is unavailable here because [describe willfulness].
V. DAMAGES CALCULATION
A. Connecticut Wage Law Damages
1. Unpaid Wages
| Category | Calculation | Amount |
|---|---|---|
| Unpaid overtime | [OT hrs] x $[premium] x [weeks] | $[Amount] |
| Minimum wage shortfall | [Hours] x $[shortfall] | $[Amount] |
| Tip credit recovery | [Hours] x $[illegal credit] | $[Amount] |
| Subtotal Unpaid Wages | $[Amount] |
2. Double Damages (Conn. Gen. Stat. Section 31-72)
| Base Amount | Double Damages | Total |
|---|---|---|
| $[Amount] | $[Amount] x 2 | $[Amount] |
B. Summary of Damages
| Category | Amount |
|---|---|
| Unpaid Wages | $[Amount] |
| Connecticut Double Damages | $[Amount] |
| FLSA Liquidated Damages (if applicable) | $[Amount] |
| Attorney's Fees (estimated) | $[Amount] |
| Costs | $[Amount] |
| TOTAL DAMAGES | $[Amount] |
VI. SETTLEMENT DEMAND
We demand payment of $[Settlement Demand Amount] to resolve all claims.
This demand expires in twenty-one (21) days on [Response Deadline Date].
VII. RESPONSE AND LITIGATION
If not resolved, we will file:
- Wage complaint with Connecticut Department of Labor
- Suit in Connecticut Superior Court seeking double damages
- Suit in U.S. District Court for the District of Connecticut for FLSA claims
VIII. DOCUMENT PRESERVATION
Preserve all time records, payroll records, personnel files, and policies immediately.
Sincerely,
[Attorney Name]
[Connecticut Juris No.]
[Firm Name]
CONNECTICUT-SPECIFIC PRACTICE NOTES
[ ] Double Damages: Automatic under Section 31-72 unless employer proves good faith
[ ] Weekly Pay Requirement: Most employers must pay weekly; violation is separate claim
[ ] Immediate Final Pay: Discharged employees must be paid next business day
[ ] High Minimum Wage: Connecticut rate ($16.35) significantly exceeds federal
[ ] Meal Period Law: Applies to manufacturing, mechanical, mercantile establishments
[ ] ECI Indexing: Minimum wage increases automatically with inflation
[ ] Connecticut DOL Contact:
- Phone: (860) 263-6790
- Website: portal.ct.gov/dol/divisions/wage-and-workplace-standards
- Wage complaint form available online