Raymond J. Donovan, Secretary of Labor v. West Coast Detective Agency, Inc. And Anja Engineering Co.

The Labor-Management Reporting and Disclosure Act of 1959, 73 Stat. 519 , P.L. 86-257, requires the disclosure and reporting of certain information from labor organizations, from management, and from certain individuals connected with both. See e.g. Section 201 ( 29 U.S.C. § 431 ) requiring the disclosure of information from labor organizations, Section 202 ( 29 U.S.C. § 432 ) from employees of labor organizations, and Section 203 ( 29 U.S.C. § 433 ) from employers. More precisely, 29 U.S.C. § 433 (a) requires reports as to:

Section 29 U.S.C. § 433 (b) requires reports from:

Section 439 of Title 29 provides criminal penalties for willful violation of these reporting requirements of the Act. Section 440 authorizes the Secretary of Labor to bring civil actions, including ones for in-junctive relief, when it appears that any person has violated or is about to violate any of the provisions of the statute.

The Secretary filed actions against Anja Engineering Co. (hereafter “Anja”) and West Coast Detective Agency, Inc. (hereafter “West Coast”) which were consolidated by the district court. It is charged that Anja hired West Coast to investigate and report on certain employee…