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For years, Connecticut’s Labor Department did not enforce a law requiring certain unions to file annual financial reports and show them to their members. The department’s explanation was simple: pursuing a violation would cost more than the $25 fine.
Two public employees have now provided what the state would not: consequences.
Corrections officer Ryan Bilodeau and criminal justice professor Earl Ormond took their unions to court. Bilodeau sued AFSCME Local 391, while Ormond sued the Congress of Connecticut Community Colleges, known as 4Cs. They came away with orders requiring the unions to meet annual financial-reporting requirements for the latest reporting year — and every year going forward.
The orders cover only those two unions. But for Local 391 and 4Cs, financial transparency is no longer optional. It is now backed by the court.
Bilodeau and Ormond filed the lawsuit together in February. They were represented by attorneys from the Fairness Center, a nonprofit law firm that represents public-sector employees in disputes involving unions, along with Connecticut attorney Craig Fishbein.
They alleged that neither union had filed the financial reports required under Connecticut law or made them available to members. Without those reports, members could not review how their dues were being spent or request a state audit.
“Nothing should be hidden from the people who are paying the dues. I shouldn’t have to fight just to get basic answers about what’s being done with my money,” Bilodeau said in a statement released by the Fairness Center.
At the center of the case is a Connecticut law that has been on the books since 1957. It requires unions with at least 25 members to file annual financial reports with the state and share them with their members. Unions covered by federal reporting law are exempt from the state requirement.
Under Connecticut law, covered unions must provide the reports to members when they are presented and keep them available upon request. Members can also ask the state to conduct an audit. Yet for years, the law appears to have been largely ignored.
As Yankee Institute previously reported, CTDOL acknowledged that it was not enforcing the statute and twice tried to persuade lawmakers to repeal it, arguing that the reports were redundant and the $25 penalty was too small to justify the cost of pursuing unions that failed to file.
In an August 2025 letter, Labor Commissioner Danté Bartolomeo called §31-77 “outdated and obsolete.” Months later, in testimony before the legislature, her own department acknowledged that the law required it to “receive, monitor, and enforce” the submission of union financial reports — and then argued for repealing it anyway because enforcement would cost more than the fine.
That is a remarkable position for an agency charged with enforcing the law. Union members were not promised financial information only when collecting the fine would turn a profit for the state. The value of a worker’s legal right does not rise or fall with how much revenue the state can collect by enforcing it.
Only after lawmakers began asking questions and Bilodeau and Ormond filed suit did CTDOL change course. It notified unions that they had to comply, issued filing instructions and created an online submission form. The department eventually did the right thing, but it took outside pressure to get there.
The lawsuit ended with court orders requiring both unions to follow the applicable financial-reporting laws. On Aug. 20, Local 391 agreed to follow §31-77 for its latest reporting year and every year after that.
The case against 4Cs took a different turn. The union argued that federal reporting rules applied to it instead of Connecticut law. Bilodeau and Ormond’s attorneys then alleged that 4Cs had not filed those reports either and sought access to its financial records dating back to 2017. Under the Aug. 19 agreement, 4Cs must now follow the federal reporting law for its most recently completed fiscal year and every year going forward.
The court did not rule on whether 4Cs had broken federal law in previous years or order it to turn over records dating back to 2017. But its defense created another problem: If federal law applied, where were the federal reports?
For Yankee Institute Labor Fellow Frank Ricci, the cases exposed a failure that went well beyond either union.
“For years, the Department of Labor tolerated a system where union members were denied information, unions ignored statutory requirements, and regulators refused to act,” Ricci said. “The Labor Commissioner took an oath to faithfully execute Connecticut law. For years, union financial transparency laws were treated as optional.”
The orders cover Local 391 and 4Cs, but CTDOL remains responsible for every other union subject to the state law. Posting a form online is not enough. The department must track who files and pursue those that do not.
An outdated $25 fine does not give CTDOL permission to ignore the law. If the penalty is too weak, lawmakers should raise it. That is an argument for fixing the law — not abandoning it.
Bilodeau and Ormond won something more important than two sets of financial reports. They turned a long-ignored legal requirement into an obligation backed by court judgments. That is a win for union members — and a reminder that the state should have acted sooner.
A right that exists only for people willing to sue is not much of a right. Connecticut needs to enforce its own law before another union member has to go to court for the transparency it already guarantees.
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