Conn. State Police Union v. Rovella, No. 20-3530 (2d Cir. 2022)
Annotate this Case
Connecticut State Police Union (“CSPU”) brought suit against the Commissioner of Connecticut’s Department of Emergency Services and Public Protection (the “Commissioner”), alleging that the FOIA-related portions of the state law violated the Contracts Clause and moved for a preliminary injunction. The law at issue is Public Act 20–1: An Act Concerning Police Accountability (“the Act”). Section 8 of the Act took aim at FOIA exemptions under Connecticut law.
The district court denied the motion primarily on the ground that the CSPU was unlikely to succeed on the merits of its claim since the law was reasonable and necessary to promote transparency and accountability for law enforcement. The Second Circuit affirmed concluding that the law served a legitimate public purpose and that the legislature, in passing it, acted not self-servingly but in the public interest.
The court explained that determine whether a law violates the Contracts Clause, it asks (1) whether the contractual impairment is substantial, (2) whether the law serves “a legitimate public purpose such as remedying a general social or economic problem,” and (3) whether the means chosen to accomplish that purpose are reasonable and necessary. Here, the Act served two legitimate public purposes: ensuring the transparency and accountability of law enforcement and promoting “FOIA’s strong legislative policy in favor of the open conduct of government and free public access to government records.” Moreover, because the district court did not err in concluding that the CSPU could not succeed on the merits of its claim, the court did not need to address the remaining prongs of the preliminary injunction test.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.