Connecticut General Statutes

Conn. Gen. Stat. § 7-470 (2026)

Prohibited acts of employers and employee organizations

✓ current as of May 2026
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(a) Municipal employers or their representatives or agents are prohibited from: (1) Interfering, restraining or coercing employees in the exercise of the rights guaranteed in section 7-468; (2) dominating or interfering with the formation, existence or administration of any employee organization; (3) discharging or otherwise discriminating against an employee because he has signed or filed any affidavit, petition or complaint or given any information or testimony under sections 7-467 to 7-477, inclusive; (4) refusing to bargain collectively in good faith with an employee organization which has been designated in accordance with the provisions of said sections as the exclusive representative of employees in an appropriate unit; (5) refusing to discuss grievances with the representatives of an employee organization designated as the exclusive representative in an appropriate unit in accordance with the provisions of said sections; (6) refusing to comply with a grievance settlement, or arbitration settlement, or a valid award or decision of an arbitration panel or arbitrator rendered in accordance with the provisions of section 7-472.

(b) Employee organizations or their agents are prohibited from: (1) Restraining or coercing (A) employees in the exercise of the rights guaranteed in subsection (a) of section 7-468, and (B) a municipal employer in the selection of his representative for purposes of collective bargaining or the adjustment of grievances; (2) refusing to bargain collectively in good faith with a municipal employer, if it has been designated in accordance with the provisions of sections 7-467 to 7-477, inclusive, as the exclusive representative of employees in an appropriate unit; (3) breaching their duty of fair representation pursuant to section 7-468; (4) refusing to comply with a grievance settlement, or arbitration settlement, or a valid award or decision of an arbitration panel or arbitrator rendered in accordance with the provisions of section 7-472.

(c) For the purposes of said sections, to bargain collectively is the performance of the mutual obligation of the municipal employer or his designated representatives and the representative of the employees to meet at reasonable times, including meetings appropriately related to the budget-making process, and confer in good faith with respect to wages, hours and other conditions of employment, or the negotiation of an agreement, or any question arising thereunder, and the execution of a written contract incorporating any agreement reached if requested by either party, but such obligation shall not compel either party to agree to a proposal or require the making of a concession.

(February, 1965, P.A. 159, S. 4; P.A. 75-189, S. 1, 2; P.A. 93-426, S. 5.)

History: P.A. 75-189 amended Subsecs. (a) and (b) to prohibit refusing to comply terms of settlements, awards and decisions; P.A. 93-426 inserted new Subsec. (b)(3) to prohibit an employee organization which represents municipal employees from breaching its duty of fair representation to its members and redesignated existing Subdiv. (3) as (4).

Cited. 154 C. 530. Plaintiff union's appeal from defendant labor relations board properly dismissed by Superior Court where there was no evidence that municipality engaged in unfair labor practices claimed in union's complaint. 159 C. 46. Cited. 171 C. 345, 349; Id., 347, 564; 175 C. 349. Standing to test constitutionality of binding arbitration provisions of Municipal Employees Relations Act discussed. 181 C. 421. Cited. 182 C. 93; 185 C. 88; 196 C. 192; 200 C. 38; 201 C. 577; 204 C. 746; 205 C. 116; 210 C. 549; 212 C. 294; 215 C. 14; 221 C. 244; 225 C. 297; 234 C. 123.

Cited. 3 CA 1; 16 CA 232; 33 CA 541.

A public announcement of plaintiff's intention to file a prohibited practice complaint against a union is protected by the Municipal Employees Relations Act when the complaint is actually filed at a later date. 31 CS 7. The clause in a contract between a municipality and its firemen which gives the firemen parity with police is a restraint upon and interference with the police union's ability to negotiate with the municipality. Id., 15, 22. Residency requirement for municipal employees was condition of employment and therefore a mandatory subject of collective bargaining, and employer's unilateral change of such condition of employment was prohibited act; failure of union to demand bargaining prior to enactment of ordinance did not constitute a waiver of its right to bargain. 36 CS 18. Cited. 40 CS 365; 42 CS 227; 43 CS 340; Id., 470.

Subsec. (a):

Subdiv. (1): Labor board cannot compel either party, directly or indirectly, to agree to any contractual position but can require that employees bargain in good faith. 160 C. 285. Cited. 171 C. 349. Subdiv. (4): Unilateral change of pension benefits by employer did not constitute refusal to bargain where union had notice of change and opportunity to negotiate the issue. 173 C. 210. Cited. 206 C. 449; 210 C. 597; 217 C. 110; 232 C. 57. Term “grievance settlement” within Subdiv. (6) encompasses an unappealed grievance decision; State Board of Labor Relations' time-tested interpretation of term is reasonable and consistent with its use as a term of art in the labor law context, there was no merit to argument that legislature intended to make a distinction between grievance decision and grievance settlement and there was nothing in statutory language or legislative history that contravened board's interpretation. 259 C. 251.

Cited. 8 CA 57. Substantial evidence supported denial by State Board of Labor Relations of union's complaint alleging that supervisory personnel employed by city department of public works engaged in prohibited conduct. 156 CA 79.

Cited. 39 CS 338.

Subsec. (c):

Collective bargaining must be taken at reasonable time relative to town's budget-making process. 160 C. 285. Cited. 162 C. 579; 171 C. 352, 353. “Conditions of employment” includes whether person shall continue in employment. Id., 553, 559, 560. Cited. 210 C. 597; 216 C. 253; 224 C. 666; 232 C. 57.

Notes of Decisions
Cited in 38 cases (3 in the last 5 years), 1967–2023 · leading case: City of Hartford v. Hartford Mun. Employees Ass'n, 788 A.2d 60 (Conn. 2002).
City of Hartford v. Hartford Mun. Employees Ass'n, 788 A.2d 60 (Conn. 2002). · cites it 29× “s, the Hartford Municipal *253 Employees Association (union) and the state board of labor relations (board), appeal 1 from the trial court’s judgment sustaining the appeal by the plaintiff, the city of Hartford (city), 2 from the board’s decision determining that the city had…”
LOCAL 1219 v. Connecticut Labor Relations Bd., 370 A.2d 952 (Conn. 1976). · cites it 10× “On May 3, 1973, the plaintiff, Local 1219, International Association of Eire Fighters, filed a complaint with the defendant board pursuant to General Statutes § 7-471 (4) 1 alleging that the borough of Naugatuck had engaged in and *345 was engaging in practices prohibited by §…”
Bd. of Educ. v. State Bd. of Labor Relations, 584 A.2d 1172 (Conn. 1991). · cites it 6× “While Winchester dealt with anti-union animus in violation of General Statutes § 7-470 (a) (1) (parallel to General Statutes § 10-153e [b] [1]), which is not alleged in the present case, and did not address the scope of *128 the discretion granted to school boards, it presented…”
Shortt v. New Milford Police Dep't, 562 A.2d 7 (Conn. 1989). · cites it 4× “To effectuate these principles of collective bargaining, the MERA makes it mandatory for local governmental employers and their employees ‘to meet at reasonable times .”
Piteau v. Bd. of Educ., 15 A.3d 1067 (Conn. 2011). · cites it 5× “” General Statutes § 7-470 (b) provides in relevant part: “Employee organizations or their agents are prohibited from .”
Local 818 of Council 4 AFSCME, AFL-CIO v. Town of East Haven, 614 A.2d 1260 (Conn. Super. Ct. 1992). · cites it 8× “On December 13, 1991, the union filed a complaint of unfair labor practices against the town, pursuant to General Statutes § 7-470 (a) (4), alleging, in essence, that the town had notified the employees of their termination in violation of article X, § 1, of the contract and…”
City of Norwich v. Norwich Fire Fighters, 377 A.2d 290 (Conn. 1977). · cites it 4× “On July 11, 1974, after a hearing, the board decided that the city's unilateral modification of benefits was a violation of § 7-470 (a) (4) [1] of the General Statutes, and ordered the city to recompute LaRochelle's benefits and to pay him accordingly, including the difference…”
City of New Haven v. Connecticut State Bd. of Labor Relations, 410 A.2d 140 (Conn. Super. Ct. 1979). · cites it 7× “General Statutes § 7-470. “To determine the question of good faith the totality of the party’s conduct throughout the negotiations must be considered.”
City of Norwalk v. Connecticut State Bd. of Labor Relations, 538 A.2d 694 (Conn. 1988). · cites it 4× “” On May 22, 1983, the defendant union filed a complaint with the Connecticut state board of labor rela *451 tions (labor board), alleging that the city was refusing to comply with a grievance settlement in violation of General Statutes § 7-470 (a) (6). 1 On April 24, 1985,…”
Town of Winchester v. Connecticut State Bd. of Labor Relations, 402 A.2d 332 (Conn. 1978). · cites it 3× “The board argues that to implement the rights given employees under § 7-468 (a), “municipal employers or their representatives are prohibited,” under § 7-470 (a) (1), from “[interfering, restraining or coercing employees in the exercise of the rights guaranteed in section 7-468.”
Greater Bridgeport Transit Dist. v. State Bd. of Labor Relations, 653 A.2d 151 (Conn. 1995). · cites it 3× “” General Statutes § 7-470 provides in relevant part: “prohibited acts of employers and employee organizations, (a) Municipal employers or their representatives or agents are prohibited from .”
Town of Stratford v. Local 134, IFPTE, 519 A.2d 1 (Conn. 1986). · cites it 2× “Under § 7-469 of the General Statutes, such parties have a duty to *589 bargain collectively “with respect to wages, hours and other conditions of employment,” as set forth in General Statutes § 7-470 (c).”
Conn. Gen. Stat. § 7-470(a)(4): 1 case
Bristol Bd. of Educ. v. State Bd. of Labor Relations, 142 A.3d 304 (Conn. App. Ct. 2016).
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