Indiana University of Pennsylvania v. Loomis

CONCURRING OPINION BY

Judge McCullough.

I concur in the result reached by the Majority. I write separately to further address the situation involving records in possession of a third party with whom an agency has contracted to perform a governmental function, as well as to cite other provisions of the Right-to-Know Law (RTKL)1 which I believe further support the Majority’s decision in this case.

In the present case, David Loomis (Requester), a journalism professor at Indiana University of Pennsylvania (University), sought records in the possession of the Foundation for Indiana University of Pennsylvania (Foundation) relating to pledges/donations for various University construction projects and minutes of meetings of the Foundation’s Board of Directors with respect to the raising and disbursement of these funds. Section 506(d) of the RTKL addresses records in the possession of a third party, providing as follows:

(1) A public record that is not in the possession of an agency but is in possession of a party with whom the agency has contracted to perform a governmental function on behalf of the agency, and which directly relates to the governmental function and is not exempt under this act, shall be considered a public record of the agency for purposes of this act.
(2) Nothing in this act shall be construed to require access to any other record of the party in possession of the public record.
(3)A request for a public record in possession of a party other than the agency shall be submitted to the open records officer of the agency. Upon a determination that the record is subject to access under this act, the open records officer shall assess the duplication fee established under section 1307(b) and upon collection shall remit the fee to the party in possession of the record if the party duplicated the record.

65 P.S. § 67.506(d)(l)-(3). In East Stroudsburg University v. Office of Open Records, 995 A.2d 496 (Pa.Cmwlth.2010), appeal denied, — Pa.-, 20 A.3d 490 (No. 439 MAL 2010, filed March 16, 2011), this Court held that records of the East Stroudsburg University Foundation directly related to its fundraising activities on behalf of East Stroudsburg University, including minutes of meetings related to the management of these funds, were subject to disclosure under section 506(d)(1). Indeed, Requester relied on our decision in East Stroudsburg University in support of his appeal to the Office of Open Records (OOR).

Generally, section 701(a) of the RTKL provides that “a public record ... shall be accessible for inspection and duplication” and “shall be provided in the medium requested if it exists in that medium; otherwise, it shall be provided in the medium in which it exists.” 65 P.S. § 67.701(a). However, I believe this section is limited to records in possession of the agency itself, and not to records in possession of a third party. This belief is buttressed by other provisions of the RTKL, namely sections 901 and 1307.

Section 901 states, in pertinent part, that “[a]ll applicable fees shall be paid in order to receive access to the record requested.” 65 P.S. § 67.901. Section *11301307(b) permits an agency to establish fees for, inter alia, duplication by photocopying, 65 P.S. § 67.1307(b), and section 1307(h) specifically permits an agency to require a requester to prepay an estimate of any fees expected to exceed $100.00, and to withhold access to records until such fees are paid, 65 P.S. § 67.1307(h).

In the present case, the Foundation provided the University with copies of 472 pages of information in response to Requester’s request. The University thereafter notified Requester that it was in receipt of the requested records and that, in accordance with section 1307(h) of the RTKL, a fee of $118.00 was due and payable before it would grant him access to these records. The University also notified Requester that certain information, including signatures, internal deliberations, and minutes disclosing donor identities, was being redacted from these records. Requester did not pay the fee; instead, requester filed an appeal with OOR challenging the redactions. Based on these facts and the statutory provisions cited above, the Majority properly concludes that Requester’s failure to pay the fee precluded his access to the records, that his appeal to OOR should have been denied, and that OOR erred in directing the University to disclose the records.2

. Act of February 14, 2008, P.L. 6, 65 P.S. §§ 67.101-67.3104.

. We note that if the records sought in this case had been original records, Requester would have had a right to inspect under section 701(a) of the.RTKL, the fees set forth in sections 901 and 1307 would not be applicable, and an appeal regarding the redactions would have been proper under section 1101(a) of the RTKL, 65 P.S. § 67.1101(a). An interesting question would arise as to the propriety of an appeal if the University had permitted Requester to inspect the redacted records without paying the fee. However, the evidence of record before this Court indicates that Requester was not permitted such an inspection and, therefore, we need not reach this issue here.