Blethen Maine Newspapers, Inc. v. State

SAUFLEY, C.J.,

concurring.

[¶ 41] I concur in the result of the above opinion, but, because I disagree with its rejection of the principles outlined in National Archives and Records Administration v. Favish, 541 U.S. 157, 124 S.Ct. 1570, 158 L.Ed.2d 319 (2004), I write separately.

[¶ 42] Any analysis of the records request in this case must begin with the acknowledgment that criminal investigation records, such as the records at issue here, are not subsumed within the general sunshine laws, and, in contrast to most government records, are not available for public review unless certain conditions have been met. It is in minimizing this distinction that the Court’s opinion goes astray.

[¶ 43] Although most public records and procedures are open to the public as a matter of declared state policy, 1 M.R.S.A. § 401 (1989), a clear exception to that policy applies to certain investigative information kept in the custody of a criminal justice agency. 1 M.R.S.A. § 402(3)(A) (Supp.2004); 16 M.R.S.A. § 614(1) (Supp. 2004). Those records are “confidential and may not be disseminated” if any one of eleven reasons for maintaining that confidentiality is demonstrated. 16 M.R.S.A. § 614(1)(A)-(K) (emphasis added). Unlike many other governmental records, and for the policy reasons stated in the dissenting opinion, the Legislature did not intend for such investigatory information to be presumed accessible to the public pursuant to Maine’s Freedom of Access Act (FOAA), 1 M.R.S.A. §§ 401-410 (1989 & Supp.2004).

[¶ 44] The distinction between ordinary public records and criminal investigation records has an historical basis. The reluctance to release investigatory records, which contain personal and private information about individual citizens gathered through the power of the State, has been addressed in a similar context in federal law. As the Supreme Court has concluded regarding public access to prosecutorial records, the central purpose of the Freedom of Information Act (FOIA), 5 U.S.C.A. § 552 (1996 & Supp.2004), is to ensure that the government’s activities are open to scrutiny, not to make available information about private citizens. See, e.g., United States Dep’t of Justice v. Reporters Comm. for Freedom of the Press, 489 U.S. 749, 774, 109 S.Ct. 1468, 103 L.Ed.2d 774 (1989).

[¶ 45] There are few discernable differences between treatment of criminal investigatory records pursuant to FOIA and the treatment of the same records pursuant to Maine’s parallel FOAA statute, and the associated statutes.12 In interpreting FOIA, the Supreme Court in Favish recognized the unique nature of investigatory records in-criminal cases and emphasizéd the prohibition on their release unless there are allegations and evidence of government misconduct that warrant disclosure of the information. 541 U.S. at 173-74,124 S.Ct. 1570.

[¶ 46] I would, as the dissent does, apply the teachings of Favish to the analysis before us. That is, I would conclude that in the absence of an allegation of governmental wrongdoing, the interests in pro*537tection of the witnesses, alleged victims, informants, and others who have been the subject of investigation would outweigh the public’s interest in the disclosure of the records.

[¶47] The question then is whether there exists in the case before us a credible allegation of governmental misconduct. Admittedly, Blethen does not specifically articulate that allegation in detail, given that the complaint and briefs in the present case were filed prior to the Supreme Court’s announcement of its decision in Favish. Nonetheless, I would conclude that the serious allegations of child sexual abuse, involving many children, made or alleged to have occurred over decades, without prosecution, is equivalent to an allegation of governmental misconduct in the present case. The number of alleged separate incidents, perpetrators, and child victims, as well as the many decades over which the allegations span, are substantial. Hence, I would conclude that the present case, unique in its factual background, presents a sufficient allegation of governmental wrongdoing to require a balancing against the private interests to be protected.13

[¶ 48] Engaging in that balancing test, I conclude that the public's interest in the records must prevail. The personal privacy of all witnesses and alleged victims will have been protected by the redaction of any information that could identify those individuals. The only remaining question of privacy relates then to the priests who were the focus of the reports, each of whom is now long deceased. In this highly unusual setting, where the only remaining privacy interests have all but evaporated over time, the reasons for allowing the prosecutor to withhold the records from the public have been greatly diminished.14

[¶ 49] In this unique setting, where the Court has protected the privacy of the alleged victims and there is no reasonable possibility that the release will interfere with law enforcement, the determination that the records may be released as redacted does not present the dangerous implications regarding law enforcement that the dissent addresses. Given the unique facts of the present case, the holding today has limited precedential force and should not have the chilling effect on prosecutorial investigations that the dissent suggests.

[¶50] Accordingly, I agree that, with appropriate protections for the personal privacy of alleged victims and witnesses, the release of these records is appropriate.

. Compare 5 U.S.C.A. § 552(b)(7)(C) (1996) (stating that ”[t]his section does not apply to matters that ... could reasonably be expected to constitute an unwarranted invasion of personal privacy”) with 16 M.R.S.A. § 614(1)(C) (Supp.2004) (stating that such records "may not be disseminated if there is a reasonable possibility that public release ... would ... [c]onstitute an unwarranted invasion of personal privacy”).

. Ordinarily, I would require compliance with the Favish standards of good faith allegations and evidence of governmental negligence or impropriety before affirming a decision that releases information excepted under FOAA. Nat’l Archives & Records Admin. v. Favish, 541 U.S. 157, 174, 124 S.Ct. 1570, 158 L.Ed.2d 319 (2004). The present case, however, poses special circumstances warranting greater flexibility in applying the FOAA analysis.

. It is important to recall that in the present case the prosecutor has not asserted any reasonable possibility that the release of the information will interfere with law enforcement. See 16 M.R.S.A. § 614(1)(A) (Supp. 2004). Indeed, the Attorney General has concluded that, among the eleven reasons legislatively set forth for maintaining the confidentiality of prosecutorial records, see 16 M.R.S.A. § 614(1)(A)-(K) (Supp.2004), the only reason that the court should consider denying Blethen’s request is the potential that dissemination could create "an unwarranted invasion of personal privacy,” id. § 614(1)(C). The Attorney General does posit that the possible invasion of privacy in this case could have a chilling effect on future investigations. The absence of any argument related to interference with prosecutions, however, necessarily focuses our analysis on the sole issue of invasion of personal privacy.