Officials at the Connecticut Department of Labor (DOL) recently took steps to enforce a state law requiring some unions to file an annual report with the department and to make that report available to their membership. The law is currently the subject of a lawsuit by members of several public-sector unions, who argue that DOL officials’ alleged failure to implement penalties and failing to enforce the law infringes on their right to be informed about their union.
DOL officials have stated in communications with legislators and in public testimony on bills seeking to eliminate the law that the statute is outdated, requires the department to collect information already publicly available through tax forms, and costs more to enforce than it collects in penalties.
At issue is a section of state statute, first enacted in 1957, requiring labor unions with at least 25 members to annually file a written financial report with the labor commissioner. The law does not apply to unions regulated by the federal Labor-Management Reporting and Disclosure Act. While the statute requires that reporting be made available to union members upon request, it also bars them from public disclosure. The law also allows union members to ask DOL officials to audit the required reports.
On May 13, DOL Commissioner Danté Bartolomeo sent an email to the co-chairs and ranking members of the legislature’s Labor and Public Employees Committee informing them that DOL officials had earlier that day sent notice to unions subject to the reporting requirement, reminding them of their requirement to comply.
The notice appears to mark a shift in DOL’s approach to the law. The agency, as alleged in a lawsuit brought by two public sector employees with pro bono legal help from The Fairness Center, has not enforced the reporting requirement or issued the $25 fine outlined in statute to unions who fail to file annual reports.
The Fairness Center, a public interest law firm “that provides free legal services to those hurt by public-sector union officials,” is representing Ryan Bilodeau and Earl Ormond in a suit against their respective unions. Bilodeau is a corrections officer and member of the American Federation of State, County, and Municipal Employees (AFCSME) Local 391. Ormond is a retired law enforcement officer who oversees Connecticut State Community College-Naugatuck Valley’s criminal justice program and is a member of the Congress of Connecticut Community Colleges (4Cs).
Despite being dues-paying members of AFCSME and 4Cs, neither Bilodeau nor Ormond has been able to obtain financial reports detailing how their dues are being spent.
“It’s simple: I want to know where my money is going. Right now, it feels like my union dues disappear from my paycheck and go to some faceless, nameless decision-maker upstate who refuses to tell me how much is being spent or why.” Earl said in a summary of the case on The Fairness Center’s website. Earl also said 4Cs promotes political causes he doesn’t agree with and that members don’t receive an explanation of how dues are spent.
According to the complaint, neither union has filed the required financial reporting, and Bilodeau and Ormond have been deprived of their rights to view the financial reporting and ask DOL to perform an audit.
The lawsuit also alleges that DOL officials were not enforcing the statute by fining labor unions who did not comply with the reporting requirement, and that DOL commissioner Bartolomeo had publicly stated she would not enforce it.
As evidence, the lawsuit cited an August 8, 2025, letter sent by Bartolomeo to Sens. Rob Sampson and Stephen Harding stating the law is “redundant, fails to offer fiscal oversight, and has no consequences for noncompliance.”
Bartolomeo added that to comply, DOL would have to “spend staff time receiving the reports and archiving them for two years, then filing papers to have them destroyed in accordance with the statute and state records retention laws” and that it would cost the department “more in staff time to go after unions who fail to repor[t] than the fine covers.”
Bartolomeo added that the information contained in the reporting is already available in IRS 990 forms, which, unlike the required fiscal reports, are disclosable to the public.
DOL officials have made similar arguments in supporting agency technical revision bills that have appeared in several recent legislative sessions and have proposed eliminating the union financial reporting requirement.
In support of the version of the bill that appeared during the 2026 legislative session, Bartolomeo wrote in testimony, “These reports disclose information that is already available to the public in IRS form 990. Complying with this statute requires CTDOL to spend staff time receiving the reports, archiving them for two years, and then filing papers to have them destroyed in accordance with the statute and state records retention laws. Additionally, the fine for unions that don’t submit a report is $25; it would cost more in CTDOL staff time to pursue unions that fail to report than the fine covers. Lastly, the reports are not disclosable to the public, whereas the IRS 990 forms are.”
The section of the bill that would have eliminated the reporting requirement was removed from substitute language advanced by the labor committee. The bill did not make it to final passage.
According to the notice DOL officials recently sent to unions subject to the law, not only are they required to file the annual reports with the DOL, they must also “deliver copies of the report to individual members of the labor organization at a regular or special meeting at which the report is presented,” and must make the report available during the following year for member inspection during regular business hours at their offices.
Bilodeau’s and Ormond’s lawsuit is still pending in Hartford Superior Court. The lawsuit seeks to have both Local 391 and 4Cs declared in violation of the financial reporting requirement. It also asks the court to issue an injunction order requiring both unions to file the required reporting for the most recent fiscal year and make it available to members. Most recently, 4Cs filed a motion to dismiss the lawsuit on the grounds that the plaintiffs failed to state a claim for which relief could be granted.
Was this article helpful?
Republish our articles for free, online or in print, under a Creative Commons license.
