American Tradition Inst. v. Rector and Visitors

CourtSupreme Court of Virginia
DecidedApril 17, 2014
Docket130934
StatusPublished

This text of American Tradition Inst. v. Rector and Visitors (American Tradition Inst. v. Rector and Visitors) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Tradition Inst. v. Rector and Visitors, (Va. 2014).

Opinion

Present: Kinser, C.J., Lemons, Goodwyn, Millette, Mims, and Powell, JJ., and Lacy, S.J.

AMERICAN TRADITION INSTITUTE, ET AL.

v. Record No. 130934 OPINION BY JUSTICE DONALD W. LEMONS April 17, 2014 RECTOR AND VISITORS OF THE UNIVERSITY OF VIRGINIA, ET AL.

FROM THE CIRCUIT COURT OF PRINCE WILLIAM COUNTY Paul F. Sheridan, Judge Designate

In this appeal, we consider whether the Circuit Court of

Prince William County ("trial court") erred by denying a

request for disclosure of certain documents under the Virginia

Freedom of Information Act ("VFOIA"), Code § 2.2-3700 et seq.,

and whether a public body may impose charges for the cost of

reviewing documents under the statutory exclusions. 1

I. Facts and Proceedings Below

Dr. Michael Mann ("Professor Mann") is a climate

scientist and former professor at the University of Virginia

1 Code § 2.2-3705.4 describes records that fall outside the scope of VFOIA as "exclusions." However, the introduction to VFOIA describes documents falling outside the scope of VFOIA as "exemptions": "Unless a public body or its officers or employees specifically elect to exercise an exemption provided by this chapter or any other statute, every meeting shall be open to the public and all public records shall be available for inspection and copying upon request. All public records and meetings shall be presumed open, unless an exemption is properly invoked." See Code § 2.2-3700(B) (emphasis added). We conclude there is no practical distinction between the use of the terms "exemption" and "exclusion" within the context of VFOIA. The Code, the parties, the trial court, and this Court's prior decisions have referred to "exclusion" and "exemption" interchangeably. ("UVA"), whose scholarly work has generated much scientific

and political interest. 2 On January 6, 2011, American

Tradition Institute and Robert Marshall (collectively, "ATI")

sent a request to UVA, a public university, seeking all of the

documents that "Dr. Michael Mann produced and/or received

while working for the University . . . and otherwise while

using its facilities and resources . . . ."

Following ATI’s January 6, 2011 request, UVA responded

that it could not comply within the pre-set five-day

compliance deadline under the VFOIA. See Code § 2.2-3704(B).

ATI and UVA negotiated over a document production and fee

schedule. After multiple email exchanges, ATI and UVA agreed

to a production schedule and a $2,000 deposit to defray costs.

On March 10, 2011, UVA received ATI’s $2,000 deposit and began

assessing its VFOIA request shortly thereafter.

On April 6, 2011, UVA sent ATI an email which read in

part:

I am writing to follow up on your Freedom of Information Act request of January 6, 2011, for a wide array of records and documents concerning former University of Virginia faculty member Michael Mann. As I previously informed you, the University has identified 34,062 potentially responsive documents on the

2 This is the second lawsuit involving Professor Mann's research to reach this Court. See Cuccinelli v. Rector & Visitors of the Univ. of Va., 283 Va. 420, 722 S.E.2d 626 (2012).

2 server we have previously agreed to be the sole repository of any possibly responsive material. We have now segregated from that mass of documents approximately 8,000 that are potentially responsive to your request and have been reviewing these documents for possible disclosure. As of today we have exhausted in this effort the initial payment you made. Consequently, we will undertake no further review unless you wish to pay another installment on our original estimate of $8,500. To date we have reviewed approximately 1,000 of the roughly 8,000 documents potentially responsive to your request. I anticipate that a first group of responsive, non-exempt documents which may be lawfully disclosed will be released to you shortly.

On April 7, 2011, ATI complied with UVA’s request and

deposited additional funds so that the University would

"continue [its] work to produce responsive documents." On

April 29, 2011, UVA’s associate general counsel indicated that

the first set of documents would be available by May 6, 2011.

However, ATI received no documents on that date so it filed a

"Petition for Mandamus and Injunctive Relief" ("Petition") in

the trial court. ATI’s Petition asked the trial court to:

(1) [O]rder [UVA] to provide the requested documents on a timely schedule; (2) bar [UVA] from demanding payment for any costs other than "accessing, duplicating, supplying, or searching for the requested records"; (3) order the Parties to engage in a process that will minimize the number of excluded documents the Court will have to review in camera; (4) order payment of the Petitioners' reasonable costs associated with the instant matter; and

3 (5) order such necessary and proper injunctive relief or other injunctive relief as this Court deems just and proper.

On May 24, 2011, the trial court entered an "Order on

Protection of Documents" which stated, in part:

The Respondent [UVA] may designate as Exempt Information any requested public record. Such designation shall constitute a representation to the Court that the Respondent . . . in good faith believes that the information so designated constitutes Exempt Information . . . . Respondent shall provide the Petitioners' [ATI] counsel . . . copies of all Exempt Information in a form to be agreed upon between the parties. . . . The Petitioners shall have 90 days after receipt of the Exempt Information to review it, negotiate with the Respondents, and if they choose, file a petition with the Court for in camera review for determination as to whether the Respondent properly designated the records as Exempt Information as defined herein. 3

In an accompanying order, the trial court also directed UVA to

release 1,793 emails "no later than 90 days after the date of

this order."

In June 2011, the trial court conducted a hearing on

whether UVA could charge ATI for the costs of reviewing the

3 ATI’s counsel was given access to all of the requested documents, so they could review the materials exclusively for the purpose of litigation. The trial court expressly limited ATI’s use of the documents to those purposes "necessary in connection with this action." The trial court forbade ATI from "disclosing the [protected documents] to any other person or entity."

4 identified records according to the requirements of various

statutory exemptions and limitations. After hearing oral

argument the trial court entered an order holding that review

of records sought pursuant to the Act to assure that the

records are responsive, are not exempt from disclosure, and

may be disclosed without violating other provisions of law is

a necessary part of the process of "accessing, duplicating,

supplying, or searching for the requested records" explicitly

authorized by § 2.2-3704(F) and therefore represented a cost

that may be imposed upon the requester under the VFOIA.

In September 2011, Professor Mann filed a motion to

intervene, arguing that the University could not sufficiently

protect his interests in privacy, academic freedom, and free

speech. The trial court granted his motion on November 1,

2011.

Throughout 2012, the parties reviewed the requested

documents and developed a series of exemplars for the trial

court to review. UVA offered 14 exemplars. ATI proposed 17.

On September 17, 2012 and April 2, 2013, the trial court

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