Frank Gerardi v. City of Bridgeport; Stephen Vitka v. City of Bridgeport

Summary

The court affirmed dismissal of the plaintiffs' actions challenging undisclosed GPS monitoring because the electronic-monitoring statute does not create an implied private right of action. Although the plaintiffs were within the class protected by the statute, its text assigns enforcement exclusively to the labor commissioner and provides no employee civil remedy, requiring the plaintiffs to exhaust the grievance procedures in their collective bargaining agreement. The court affirmed on this alternate jurisdictional ground rather than the trial court's rationale concerning whether the monitoring occurred on the employer's premises.