A Connecticut Superior Court judge sided with two Connecticut public sector union members who sued their respective unions for failure to follow a 1957 law requiring unions to submit financial disclosures to the Department of Labor for any member who requested to view them. Department of Labor Commissioner Dante Bartolomeo initially ignored and dismissed that reporting requirement, saying it was, “redundant, fails to offer fiscal oversight, and has no consequences for noncompliance”

Department of Correction Officer Ryan Bilodeau and Criminal Justice Professor Earl Ormond successfully won a court order requiring their unions to file the required financial disclosures for this year and every year moving forward, in accordance with Connecticut law, which has been on the books for sixty years but hasn’t been enforced. 

In Earl’s case, the court required his union, the Congress of Connecticut Community Colleges (4Cs), to file the required federal financial disclosures because the union also represented private sector employees and was therefore subject to federal reporting requirements, but hadn’t done so.

In their court complaint, Bilodeau and Ormond argued they were deprived of their right to review their union’s financial reports, and were deprived of their, “right to ask the state to audit those reports.”

“Although Section 31-77 includes an administrative enforcement mechanism for noncompliance—namely, the imposition of a fine—the Labor Commissioner has publicly pronounced that she does not, and will not, use that mechanism,” attorney and State Rep. Craig Fishbein, R-Wallingford, and Fairness Center Attorney Nathan McGrath wrote in the court complaint. “Indeed, based on information and belief, the Labor Commissioner has never imposed the fine on the Defendant labor unions for their failure to comply with the statute.”

Failure to comply with Connecticut’s financial disclosure law carries a $25 penalty, and DOL Commissioner Bartolomeo argued before the Labor and Public Employees Committee that enforcing the law would cost more than the fine, and that unions were already required to file federal financial disclosures. 

However, the law also allows a union member to request in writing that the DOL audit those reports. The Connecticut law was passed in accordance with passage of the federal Labor Management Reporting and Disclosure Act of 1959, which was a response to union corruption issues at the time.

“Union members deserve transparency, especially when our dues may be used for political causes we don’t support,” Ormond said in a press release. “I felt like my dues disappeared from my paycheck while I was left in the dark. This judgment helps to show workers across Connecticut that they can demand the transparency the law requires.”

The issue of Connecticut’s lack of enforcement of this law was initially brought to public attention by Yankee Institute, a free-market based think tank, in 2021. 

“This is a victory for every Connecticut worker who pays union dues,” said Yankee Institute President Carol Platt Liebau in a press release. “If a union is taking money from workers’ paychecks, those workers have a right to know where that money is going. Financial disclosure laws mean little if unions can simply ignore them. These judgments demonstrate that Connecticut’s transparency laws are not optional and union members can hold their unions accountable when those laws are ignored.”

According to an August 2025 letter from Bartolomeo to Senators Rob Sampson, R-Wolcott, and Stephen Harding, R-Brookfield, Yankee Institute Labor Fellow and former New Haven Firefighters Union President Frank Ricci was the only person to request those financial disclosures in 2021, and that no union member had requested those reports, “as far as anyone at DOL can remember.”

Bartolomeo unsuccessfully pushed to eliminate the financial disclosure language from state statute in 2025, and again in 2026 as Bilodeau and Ormond’s case was proceeding through the court system. In testimony before the Labor and Public Employees Committee in 2026, the DOL Commissioner again argued the statute was no longer necessary and that no union member had ever requested these documents.

“This is something we have not been doing for some time,” Bartolomeo said during testimony, adding that she was unaware of the law when she became commissioner. “This is not originating from a union request; this is originating from a lot of focus that was brought to this issue and criticism of the agency for not doing this.”

“I’ve not even had a situation where somebody came to me and could not get the information,” Bartolomeo continued.

However, emails obtained by Ricci show two teacher union members requesting the reports from DOL in 2021, and DOL Legal Director Heidi Lane replying that the department had no such records or directing them to federal websites, which also did not contain financial disclosures for those members’ respective unions.

“There are documented instances in which public employees requested financial reports through the Department of Labor and did not receive meaningful assistance,” Ricci wrote in testimony. “If the Department of Labor has not been receiving required reports, the appropriate response is compliance and enforcement — not statutory retreat. Lowering the standard because compliance has lagged only rewards noncompliance.”

While Bartolomeo argued that unions already file public financial disclosure reports, Bilodeau’s union, AFSCME Local 391, does not have a publicly available federal report or 990 filing. Rather, the local is part of its parent organization, AFSCME Council 4, which issues an LM2 report, but does not contain specific details about Local 391’s finances. 

Labor unions do have to file financial disclosure reports with the federal government, like LM2 reports. However, those reports are only publicly available if they involve both public and private sector unions, so many teacher unions, like the Connecticut Education Association, or locals specifically for public employees, are exempt from those federal reporting requirements. 

In May 2026, the Connecticut DOL issued a letter instructing state unions on how to comply with the law and created an online portal for their annual state reports.

“Ryan and Earl demanded that their unions follow the law—it’s that simple,” said Nathan McGrath, president and general counsel at the Fairness Center, the nonprofit public-interest law firm that represented Bilodeau and Ormond. “Their lawsuit helped prompt the state to remind unions of their reporting obligations, and the judgments they won have sent an even clearer message to union officials across Connecticut: follow the law, or your members may take you to court—and win.”

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