Conn. Gen. Stat. » Title 31 — LABOR · Chapter 562 — Labor Disputes
Connecticut General Statutes

Conn. Gen. Stat. § 31-115 (2025)

Hearings. Temporary order

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No court shall have jurisdiction to issue a temporary or permanent injunction in any case involving or growing out of a labor dispute, except after hearing the testimony of witnesses in open court, with opportunity for cross-examination, in support of the allegations of a complaint made under oath, and testimony in opposition thereto, if offered, and except after a finding of facts by the court, to the effect: (a) That unlawful acts have been threatened and will be committed by a person or persons unless such person or persons are restrained therefrom, but no injunction or temporary restraining order shall be issued on account of any threat or unlawful act except against the person or persons, association or organization making the threat or committing the unlawful act or actually authorizing or ratifying the same after actual knowledge thereof; (b) that substantial and irreparable injury to the complainant or his property will follow; (c) that as to each item of relief granted greater injury would be inflicted upon the complainant by the denial of relief than would be inflicted upon the defendants by the granting of relief; (d) that the complainant has no adequate remedy at law; and (e) that the public officers charged with the duty to protect the complainant's property are unable or unwilling to furnish adequate protection. Such hearing shall be held after notice thereof has been given, in such manner as the court directs, to all known persons against whom relief is sought, provided, if a complainant also alleges that, unless a temporary restraining order is issued without notice, substantial and irreparable injury to the complainant or his property will be unavoidable, such a temporary restraining order may be issued upon testimony under oath, sufficient, if sustained, to justify the court in issuing a temporary injunction upon a hearing after notice. Such temporary restraining order shall be effective for no longer than three days and shall become void at the expiration of such three days, provided, if a hearing on a temporary injunction has begun before the expiration of such three days, the restraining order may, in the court's discretion, be modified or continued until a decision is reached by said court. No temporary restraining order or temporary injunction shall be issued except on condition that the complainant shall first file an undertaking, with surety satisfactory to the court granting the injunction, to answer all damages in case the plaintiff in the action in which the injunction is applied for fails to prosecute the action to effect.

(1949 Rev., S. 7411; 1967, P.A. 483.)

History: 1967 act added Subdiv. (e) requiring finding of fact that public officers charged with duty to protect complainant's property are unable or unwilling to furnish adequate protection before injunction may be issued.

Cited. 134 C. 626. Picketing to force plaintiff to employ only union members is unlawful and injunctive relief held warranted. 139 C. 95. Cited. 145 C. 77. Money damages held not an adequate remedy when plaintiff harmed by unlawful picketing. 146 C. 93. Where temporary injunction was issued ex parte, without notice, full hearing and finding of facts, plaintiffs were wrongfully enjoined. 148 C. 568. Cited. 177 C. 17; 186 C. 247; 188 C. 196; 190 C. 371; 203 C. 624.

Cited. 26 CA 610.

“Each item of relief” means the various prohibitory mandates of the injunction. 8 CS 331. Cited. 19 CS 452. Requirement that unlawful acts have been threatened or will be committed not given literal interpretation; court may take jurisdiction where equitable relief alone is sought; whether damages are irreparable depends more on nature of right affected than upon pecuniary loss. 27 CS 156. Cited. 34 CS 157; 42 CS 227.

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Notes of Decisions
Cited in 11 cases (2 in the last 5 years), 1961–2023 · leading case: Hartford Div. v. Amalgamated Local Union 376, 461 A.2d 422 (Conn. 1983).
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Hartford Div. v. Amalgamated Local Union 376, 461 A.2d 422 (Conn. 1983). · cites it 14× “The plaintiff must establish “(a) [t]hat unlawful acts have been threatened and will be committed by a person or persons unless such person or persons are restrained therefrom, but no injunction or temporary restraining order shall be issued on account of any threat or unlawful…”
Local 818 of Council 4 AFSCME, AFL-CIO v. Town of East Haven, 614 A.2d 1260 (Conn. Super. Ct. 1992). · cites it 8× “§ 107 , provides that temporary injunctive relief may not be granted except after a finding of facts by the court to the effect that: (1) unlawful acts have been threatened and will be committed absent an order; (2) substantial and irreparable injury to the complainant will…”
Int'l Ass'n of Firefighters, Local 786 v. Serrani, 602 A.2d 1067 (Conn. App. Ct. 1992). · cites it 6× “General Statutes § 31-115 sets forth five facts that the trial court must find to exist before it may grant injunctive relief in a labor dispute.”
Connecticut Foundry Co. v. Int'l Ladies Garment Workers Union, 411 A.2d 1 (Conn. 1979). · cites it 2× “1 On the basis of the claims that they did not voluntarily agree to a further extension of the injunction and that their request for a full hearing in open court on the merits pursuant to General Statutes § 31-115 was improp *19 erly denied, 2 the defendants have appealed from…”
Connecticut State Employees Ass'n v. Am. Fed'n of State, 448 A.2d 1341 (Conn. 1982). · cites it 3× “The court has further concluded that in enacting § 7411, the predecessor statute to § 31-115, the state legislature intended “to require bonds from [a] plaintiff for the payment of damages to [a] defendant in case of a final decision adverse to the injunction,” and “to provide…”
Rustici v. Malloy, 758 A.2d 424 (Conn. App. Ct. 2000). · cites it 4× “” 6 Furthermore, “General Statutes § 31-115 7 sets forth five facts that the trial court must find to exist before it may grant injunctive relief in a labor dispute.”
Div. 163 of the Amalgamated Ass'n of Street Employees of Am. v. Connecticut Co., 173 A.2d 130 (Conn. 1961). · cites it 2× “See General Statutes § 31-115. Also on the same day, October 15, the company furnished the bond, approved by the judge; the defendant casualty company was surety on the bond.”
Local 45, United Rubber, Cork, Linoleum & Plastic Workers of Am. v. Uniroyal, Inc., 232 A.2d 763 (Conn. Super. Ct. 1967). · cites it 6× “The application for an injunction followed, the union claiming, under § 31-115 of the General Statutes, an unlawful breach of the agreement of April 18, 1967; substantial and irreparable injury; greater injury to it than to the company; and no adequate remedy at law.”
Anaconda Co. v. United Auto., 382 A.2d 544 (Conn. Super. Ct. 1977). “In the case before the court, after an ex parte hearing held on October 7, 1977, pursuant to the provisions of § 31-115 of the General Statutes, a temporary restraining order, effective as of October 10, 1977, for a three-day period, was issued by the court proscribing certain…”
Smith v. Supple, 293 A.3d 851 (Conn. 2023). “See General Statutes § 31-115 (temporary injunctive relief requires ‘‘finding of facts by the court’’ that (a) unlawful acts have been threatened and are forthcoming; (b) substantial and irreparable injury; (c) harm to complainant; (d) no adequate remedy at law; and (e)…”
Smith v. Supple, 293 A.3d 851 (Conn. 2023). “See General Statutes § 31-115 (temporary injunctive relief requires ‘‘finding of facts by the court’’ that (a) unlawful acts have been threatened and are forthcoming; (b) substantial and irreparable injury; (c) harm to complainant; (d) no adequate remedy at law; and (e)…”
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