Connecticut General Statutes

Conn. Gen. Stat. § 1-214 (2026)

(Formerly Sec. 1-20a). Public employment contracts as public record. Agency response to request for disclosure of personnel or medical files. Objection to disclosure

✓ current as of May 2026
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(a) Any contract of employment to which the state or a political subdivision of the state is a party shall be deemed to be a public record for the purposes of section 1-210.

(b) (1) Whenever a public agency receives a request to inspect or copy records contained in any of its employees' personnel or medical files and similar files, and the agency reasonably believes that the disclosure of such records would legally constitute an invasion of privacy, the agency shall immediately notify in writing (A) each employee concerned, provided such notice shall not be required to be in writing where impractical due to the large number of employees concerned, and (B) the collective bargaining representative, if any, of each employee concerned.

(2) Whenever a public agency receives a request to inspect or copy records contained in any of its employees' personnel or medical files and similar files, and the agency reasonably believes that the disclosure of such records would not legally constitute an invasion of privacy, the agency shall first disclose the requested records to the person making the request to inspect or copy such records and subsequently, within a reasonable time after such disclosure, make a reasonable attempt to send a written or an electronic copy of the request to inspect or copy such records, if applicable, or a brief description of such request, to each employee concerned and the collective bargaining representative, if any, of each employee concerned.

(3) Nothing in this section shall require an agency to withhold from disclosure the contents of personnel or medical files and similar files when it does not reasonably believe that such disclosure would legally constitute an invasion of personal privacy.

(c) A public agency which has provided notice under subdivision (1) of subsection (b) of this section shall disclose the records requested unless it receives a written objection from the employee concerned or the employee's collective bargaining representative, if any, within seven business days from the receipt by the employee or such collective bargaining representative of the notice or, if there is no evidence of receipt of written notice, not later than nine business days from the date the notice is actually mailed, sent, posted or otherwise given. Each objection filed under this subsection shall be on a form prescribed by the public agency, which shall consist of a statement to be signed by the employee or the employee's collective bargaining representative, under the penalties of false statement, that to the best of his knowledge, information and belief there is good ground to support it and that the objection is not interposed for delay. Upon the filing of an objection as provided in this subsection, the agency shall not disclose the requested records unless ordered to do so by the Freedom of Information Commission pursuant to section 1-206. Failure to comply with a request to inspect or copy records under this section shall constitute a denial for the purposes of section 1-206. Notwithstanding any provision of this subsection or subsection (b) of section 1-206 to the contrary, if an employee's collective bargaining representative files a written objection under this subsection, the employee may subsequently approve the disclosure of the records requested by submitting a written notice to the public agency.

(P.A. 73-271; P.A. 78-331, S. 1, 58; P.A. 87-285, S. 1; P.A. 88-353, S. 1, 4; P.A. 92-207, S. 1; P.A. 18-93, S. 1.)

History: P.A. 78-331 deleted reference to repealed Sec. 1-20; P.A. 87-285 added Subsecs. (b) and (c), granting employees the right to object to the disclosure of their personnel or medical files and establishing standards and procedures for such objections; P.A. 88-353 added Subsec. (b)(2) re notice to collective bargaining representative, and amended Subsec. (c) to allow collective bargaining representative to object to disclosure of records, to require objection to be on agency form signed under penalties of false statement and to allow employee to approve disclosure if collective bargaining representative objects; P.A. 92-207 amended Subsec. (c) by increasing the number of days for receiving a written objection from an employee or collective bargaining representative re disclosure of records from four to seven and increasing the time limit re the nonreceipt of the written notice from seven to nine; Sec. 1-20a transferred to Sec. 1-214 in 1999; P.A. 18-93 amended Subsec. (b) to designate existing provisions re request to inspect or copy records agency reasonably believes disclosure would constitute invasion of privacy as new Subdiv. (1) and amend same to redesignate existing Subdivs. (1) and (2) as Subparas. (A) and (B), add new Subdiv. (2) re request to inspect or copy records agency reasonably believes disclosure would not constitute invasion of privacy, designate existing provisions re disclosure when agency does not reasonably believe disclosure would legally constitute invasion of privacy as Subdiv. (3), and made technical and conforming changes.

Annotations to former section 1-20a:

Cited. 206 C. 449; 217 C. 153; Id., 193; 218 C. 256; Id., 757; 220 C. 225; 221 C. 217; Id., 300; Id., 393; Id., 482; Id., 549; 222 C. 621; 227 C. 751; 228 C. 158; Id., 271; 233 C. 28.

Cited. 16 CA 49; 22 CA 316; 29 CA 821; 35 CA 111; 37 CA 589; 42 CA 402; 43 CA 133.

Cited. 42 CS 84; Id., 129; Id., 291.

Annotation to present section:

Subsec. (b):

Commission must ensure that employee whose records are the subject of an appeal has received notice of proceedings where employer has failed to give required notice. 60 CA 584.

Notes of Decisions
Cited in 12 cases (3 in the last 5 years), 2000–2023 · leading case: Rocque v. Freedom of Info. Comm'n, 774 A.2d 957 (Conn. 2001).
Rocque v. Freedom of Info. Comm'n, 774 A.2d 957 (Conn. 2001). · cites it 8× “4 *655 Pursuantto General Statutes § 1-214 (b), 5 the department notified the employees involved, including the complainant and the department manager, of their right to object to the disclosure of the records.”
Pane v. City of Danbury, 841 A.2d 684 (Conn. 2004). · cites it 5× “…embodied in General Statutes § 1-210 (b) (2), formerly § 1-19 (b) (count one); violations of § 1-210 (b) (2) and General Statutes § 1-214 (b), 1 formerly *671 § l-20a (b) (count two); deprivation of the plaintiffs state and federal constitutional right to privacy in…”
Groton Police Dep't v. Freedom of Info. Comm'n, 931 A.2d 989 (Conn. App. Ct. 2007). · cites it 6× “For example, General Statutes § 1-214 (b) provides in relevant part: “Whenever a public agency receives a request to inspect or copy records contained in any of its employees’ personnel or medical files and similar files and the agency reasonably believes that the disclosure of…”
Dir., Ret. & Benefits Servs. Div. v. Freedom of Info. Comm'n, 29 Media L. Rep. (BNA) 2358 (Conn. 2001). · cites it 4× “Pursuant to General Statutes § 1-214 (b) and (c), 6 the department distributed notices to the thirty-eight employees subject to Youngquist’s disclosure request, advising them that their home addresses had been requested and that they could file written objections to *768 their…”
Tompkins v. Freedom of Info. Comm'n, 46 A.3d 291 (Conn. App. Ct. 2012). · cites it 4× “” In its October 22, 2007 response to the request, the town refused to produce the requested records, claiming that it was prohibited from so doing in light of applicable statutory exemptions under § 1-210 and an objection to disclosure filed by the plaintiff under General…”
Clerk of the Superior Court v. Freedom of Info. Comm'n, 895 A.2d 743 (Conn. 2006). · cites it 2× “tatutes § 1-206(a) provides: "Any denial of the right to inspect or copy records provided for under section 1-210 shall be made to the person requesting such right by the public agency official who has custody or control of the public record, in writing, within four business…”
Dep't of Pub. Saf. v. Freedom of Info. Comm'n, 6 A.3d 763 (Conn. 2010). “ovides in relevant part: “(a) Any denial of the right to inspect or copy records provided for under section 1-210 shall be made to the person requesting such right by the public agency official who has custody or control of the public record, in writing, within four business…”
Chairman, Bd. of Educ. v. Freedom of Info. Comm'n, 760 A.2d 534 (Conn. App. Ct. 2000). · cites it 8× “to 1997) § l-20a (b), now § 1-214 (b), 8 a prerequisite to *588 the commission’s issuing an order requiring disclosure of said documents? In its supplemental brief, the board states that the superintendent did not receive notice of Casey’s request or of the proceedings before…”
Lindquist v. Freedom of Info. Comm'n, 203 Conn. App. 512 (Conn. App. Ct. 2021). “to 2015) § 1-214, and chapters 563 and 563a of the General Statutes, (2) the trial court improp- erly concluded that the commission properly applied § 1-210 (b) (1) and (e) (1) of the act to the records at issue, (3) the trial court improperly rejected the due process claim…”
First Selectman v. Freedom of Info. Comm'n, 758 A.2d 429 (Conn. App. Ct. 2000). · cites it 2× “General Statutes § 1-214 provides in relevant part: “(b) Whenever apublic agency receives a request to inspect or copy records contained in any of its employees’ personnel or medical files and similar files and the agency reasonably believes that the disclosure of such records…”
Giuliano v. Freedom of Info. Comm'n (Conn. App. Ct. 2022). · cites it 4× “’’ Pursuant to General Statutes § 1-214 (b) (1),3 the city gave notice to all employees whose names appeared in the responsive documents and a number of employees objected in writing to the disclo- sure of their identities.”
Moore v. Sequeira (D. Conn. 2023). · cites it 4× “” Conn. Gen. Stat. § 1-214 (b)(1). If so, the agency must “immediately notify in writing” the employee concerned and the employee’s collective bargaining representative.”
— Conn. Gen. Stat. § 1-214(b)(2) — 1 case
Moore v. Sequeira (D. Conn. 2023). “” Conn. Gen. Stat. § 1-214 (b)(1). If so, the agency must “immediately notify in writing” the employee concerned and the employee’s collective bargaining representative.”
— Conn. Gen. Stat. § 1-214(b)(3) — 1 case
Moore v. Sequeira (D. Conn. 2023). “” Conn. Gen. Stat. § 1-214 (b)(1). If so, the agency must “immediately notify in writing” the employee concerned and the employee’s collective bargaining representative.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.