Carroll County E911 v. Aishah Hasnie

CourtIndiana Court of Appeals
DecidedApril 29, 2020
Docket19A-MI-2682
StatusPublished

This text of Carroll County E911 v. Aishah Hasnie (Carroll County E911 v. Aishah Hasnie) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carroll County E911 v. Aishah Hasnie, (Ind. Ct. App. 2020).

Opinion

FILED Apr 29 2020, 10:33 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

ATTORNEY FOR APPELLANT ATTORNEYS FOR APPELLEE Mark J. Crandley Margaret M. Christensen Barnes & Thornburg LLP Mark R. Molter Indianapolis, Indiana Dentons Bingham Greenebaum LLP ATTORNEYS FOR AMICUS – INDIANA Indianapolis, Indiana PROSECUTING ATTORNEYS COUNCIL ATTORNEY FOR AMICI – REPORTER’S COMMITTEE Christopher W. Naylor FOR FREEDOM OF THE Executive Director PRESS, ET AL. J. Thomas Parker Deputy Director Michael A. Wilkins Indiana Prosecuting Attorneys Council Broyles Kight & Ricafort Indianapolis, Indiana ATTORNEYS FOR AMICUS – STATE OF INDIANA Curtis T. Hill, Jr. Attorney General of Indiana Sierra A. Murray Deputy Attorney General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

Court of Appeals of Indiana | Opinion 19A-MI-2682 | April 29, 2020 Page 1 of 16 Carroll County E911, April 29, 2020 Appellant-Defendant, Court of Appeals Case No. 19A-MI-2682 v. Appeal from the Marion Superior Court Aishah Hasnie, The Honorable Timothy W. Appellee-Plaintiff. Oakes, Judge Trial Court Cause No. 49D02-1802-MI-7041

Najam, Judge.

Statement of the Case [1] Carroll County E911—the 9-1-1 call and dispatch center for Carroll County

(“the Dispatch Center”)—appeals the trial court’s entry of summary judgment

for Tribune Broadcasting Indianapolis, LLC, d/b/a Fox 59 (“Fox 59”), on Fox

59’s complaint seeking disclosure of certain 9-1-1 calls pursuant to Indiana’s

Access to Public Records Act, Ind. Code §§ 5-14-3-1 to -10 (2019) (“APRA”).

The Dispatch Center raises the following two issues for our review:

1. Whether the 9-1-1 calls in question were records that may be excepted from public disclosure under APRA.

Court of Appeals of Indiana | Opinion 19A-MI-2682 | April 29, 2020 Page 2 of 16 2. Whether the trial court abused its discretion when it permitted Fox 59 to substitute itself for an employee as the real party in interest in this matter after the employee had left her employment with Fox 59.

[2] The 9-1-1 calls at issue here were originally received and recorded by the

Dispatch Center but, thereafter, acquired by local law enforcement agencies

pursuant to a criminal investigation. Those agencies asked the Dispatch Center

not to honor Fox 59’s APRA request because public disclosure of the calls

could compromise their investigation. APRA allows for otherwise public

records to be withheld from public disclosure when those records are the

investigatory records of law enforcement agencies. Accordingly, we hold that,

pursuant to that exception, Fox 59 is not entitled to summary judgment against

the Dispatch Center. We therefore reverse the trial court’s entry of summary

judgment for Fox 59 on the APRA issue. However, we affirm the trial court’s

substitution of Fox 59 as the real party in interest.

Facts and Procedural History [3] The Dispatch Center “is a public safety answering and dispatch point for police,

fire, emergency medical[,] and emergency management service” for Carroll

County. Appellant’s App. Vol. III at 6. Its mission is to “serve as the

communications link between the citizen and public safety agencies; make

accurate identification of the citizen’s location and public safety response needs;

quickly and accurately activate public safety services; [and] provide

communications support and coordination of all public safety and supporting

agencies.” Id. The Dispatch Center’s Lead Communicator manages the Court of Appeals of Indiana | Opinion 19A-MI-2682 | April 29, 2020 Page 3 of 16 Dispatch Center and its employees and is required to inform the Carroll County

Commissioners’ Office of any employee discipline within the Dispatch Center.

Id. at 42.

[4] In November of 2016, four children died in a residential house fire in Flora,

which is in Carroll County. Multiple 9-1-1 callers reported the fire to the

Dispatch Center, which recorded the calls (“the 9-1-1 calls”). Indiana State

Police Detective Benjamin Rector was part of the team that then investigated

the fire, which became a criminal investigation that remains ongoing. He

would later describe the 9-1-1 calls as follows:

7. The [9-1-1 calls] capture details regarding the fire relevant to the law enforcement investigation.

8. The public release of [the 9-1-1 calls] would harm the investigation.

9. This is because the recordings contain details about the fire not publicly known, including who witnessed the fire, what they reported about what they saw, when they witnessed it, the witnesses’ awareness[es] of who occupied the home where the fire occurred, and conversations occurring in the background of the calls.

10. Allowing these details to become publicly known would undermine the ongoing investigation because these details take significance when investigators interview witnesses and potential suspects.

11. If the details recorded in the [9-1-1 calls] became publicly known, potential suspects and witnesses could use this Court of Appeals of Indiana | Opinion 19A-MI-2682 | April 29, 2020 Page 4 of 16 information to evade questioning and it would limit investigators[’] ability to know what information suspects have first-hand knowledge of and which information witnesses learned through public disclosure of evidentiary material like [the 9-1-1 calls].

12. Because the investigation is ongoing, investigators cannot know all details in the recordings that may be of importance as the investigation continues. Releasing the records at this time may disclose facts of significance that potential suspects could use in attempting to evade prosecution.

13. Gathering [9-1-1] recordings is a common investigative technique in homicide and other major investigations. I have on several earlier occasions preserved [9-1-1] recordings that were later used as evidence in criminal prosecutions.

Appellant’s App. Vol. IV at 57.

[5] In June of 2017, Aishah Hasnie, then a news reporter for Fox 59, requested that

the Dispatch Center release the 9-1-1 calls to her under APRA. The Dispatch

Center declined, stating that, because “the fire is still under police

investigation” by the Carroll County Sheriff’s Department and the Carroll

County Prosecutor, those agencies were “exercising their discretion not to

permit disclosure of such recording or recordings at this time, pursuant to

[Indiana Code Section] 5-14-3-4(b)(1).” Appellant’s App. Vol. II at 15.

[6] Hasnie requested that the Indiana Public Access Counselor (the “PAC”) review

her APRA request and the Dispatch Center’s denial of her request. The PAC

opined that the Dispatch Center was required under APRA to disclose the 9-1-1

Court of Appeals of Indiana | Opinion 19A-MI-2682 | April 29, 2020 Page 5 of 16 calls. However, the Dispatch Center disagreed and continued not to disclose

the 9-1-1 calls. Hasnie then filed her complaint in the Marion Superior Court.

[7] In April of 2019, Fox 59 moved to substitute itself as the real party in interest

for Hasnie, who had left her employment there, and also moved for summary

judgment. The Dispatch Center objected to the substitution of parties and filed

its response to the summary judgment motion. In its response, the Dispatch

Center designated the affidavit of Detective Rector. The trial court granted Fox

59’s motion to substitute itself for Hasnie. The court then entered summary

judgment for Fox 59. 1 This appeal ensued.

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