Conn. State Police Union v. Rovella, 36 F.4th 54

In 2018 Connecticut State Police Union (CSPU) and the State executed a collective bargaining agreement (2018–2022) that added a FOIA exemption for personnel/internal affairs records with dispositions of “Exonerated, Unfounded or Not Sustained.”
Connecticut statute then allowed collective-bargaining terms to override general statutes; the legislature ratified the 2018 agreement in May 2019.
After George Floyd’s murder and nationwide protests, Connecticut convened a July 2020 special session and enacted Public Act 20-1 to enhance police transparency and accountability.
Sections 8–9 of the Act repealed the statute giving CBAs precedence over FOIA and barred CBAs from prohibiting disclosure of disciplinary matters, thereby nullifying the CSPU’s exemption.
CSPU sued the Commissioner under the Contracts Clause and sought a preliminary injunction; the district court denied the injunction on the ground that the CSPU was unlikely to succeed on the merits.
The Second Circuit affirmed: it concluded the Act served legitimate public purposes (transparency and police accountability), the legislature acted in the public interest (not self-servingly), and the impairment was a reasonable and necessary response.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Act substantially impaired the CBA	CSPU: Act nullifies negotiated FOIA exemption and thus substantially impairs the contract	State: any impairment does not automatically violate Contracts Clause; proceed to public-purpose inquiry	Court: assumed (without deciding) impairment but moved to legitimacy/means analysis
Whether the Act served a legitimate public purpose	CSPU: legislature aimed to undermine the CBA (special-interest targeting)	State: Act advances transparency and police accountability after Floyd protests	Held: Act serves legitimate public purposes (open government; police accountability)
Proper standard of deference when a state impairs a public contract	CSPU: demands less deference (or stricter review) because state is a party to the contract	State: absent indicia of state self‑interest, courts should defer to legislature’s judgment	Held: adopt presumption of validity absent signs of self‑serving motive; plaintiff bears burden to show less deference applies
Whether the Act’s means were reasonable and necessary	CSPU: less intrusive alternatives/timing (wait until CBA expiration) or narrower disclosures could have been used	State: urgent public need justified timely, limited-duration measures; FOIA retains privacy safeguards	Held: Act was a reasonable and necessary response; CSPU failed to show law unreasonable or unnecessary; injunction properly denied

Buffalo Teachers Federation v. Tobe, 464 F.3d 362 (2d Cir. 2006) (sets three-step Contracts Clause inquiry for public-contract impairments)
Sullivan v. Nassau Cnty. Fin. Auth., 959 F.3d 54 (2d Cir. 2020) (distinguishes deference levels and identifies indicia of state self-interest)
Energy Reserves Group, Inc. v. Kansas Power & Light Co., 459 U.S. 400 (1983) (Contracts Clause framework for assessing impairment)
U.S. Trust Co. of N.Y. v. New Jersey, 431 U.S. 1 (1977) (limits deference where state financial self-interest is implicated)
Melendez v. City of New York, 16 F.4th 992 (2d Cir. 2021) (distinguishes public vs. private contract impairment contexts)
Home Bldg. & Loan Ass'n v. Blaisdell, 290 U.S. 398 (1934) (recognizes state power to adopt temporary contractual impairments in emergency)
Igneri v. Moore, 898 F.2d 870 (2d Cir. 1990) (articulates the public-accountability value of publicity)