E. Greim v. PSP (OOR)

CourtCommonwealth Court of Pennsylvania
DecidedJanuary 17, 2025
Docket105 C.D. 2024
StatusPublished

This text of E. Greim v. PSP (OOR) (E. Greim v. PSP (OOR)) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
E. Greim v. PSP (OOR), (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Edward Greim, : Petitioner : : v. : No. 105 C.D. 2024 : Argued: November 7, 2024 Pennsylvania State Police (Office : of Open Records), : Respondent :

BEFORE: HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE STACY WALLACE, Judge HONORABLE MARY HANNAH LEAVITT, Senior Judge

OPINION BY SENIOR JUDGE LEAVITT FILED: January 17, 2025

Edward Greim (Requester) petitions for review of a January 12, 2024, final determination of the Pennsylvania Office of Open Records (OOR) denying his appeal under the Right-to-Know Law (RTKL).1 In so doing, the OOR upheld the decision of the Pennsylvania State Police (State Police) to deny Requester’s request for certain email records of its personnel and officers as not sufficiently specific. Upon review, we reverse. Background On October 6, 2023, Requester submitted to the State Police a written request under the RTKL (Request) for the following records: 1. Any and all communications relating to Mark Houck’s September 20, 2022, indictment or Mark Houck’s September 23, 2022, arrest. 2. Any and all communications relating to the Houck family.

1 Act of February 14, 2008, P.L. 6, 65 P.S. §§67.101-67.3104. 3. Any and all communications relating to any request for assistance from [State Police] officers in the arrest of Mark Houck. 4. Any and all communications relating to pro-life people OR Catholicism (including adherents of Catholicism) OR Christianity (including adherents of Christianity). 5. Any and all communications regarding or relating to the organization, Kings Men. 6. Any and all communication relating to communications with any other local, state, or federal elected official, or the [Federal Bureau of Investigation] Philadelphia field office, regarding any of the above topics. 7. All emails generate[d] by, received by, or exchanged between or including [State Police] personnel or officers, including the following search terms: “Houck,” “King’s Men,” “Kings Men,” “abortion,” “pro-life,” “prolife,” “Christian,” “Christianity,” “Catholic,” “Catholicism,” “radial-traditionalist, Catholic,” “radical traditional Catholic,” “RTC,” and/or “Roman Catholic.” For purposes of Requests 1-6, we believe that communications may exist between or including the following individuals: Trooper Michael Rogers, Trooper Juan Barrios, the supervisor(s) of Trooper Michael Rogers and Juan Barrios, or any officer that was involved in the approval or investigation of the decision to have Michael Rogers and Juan Barrios participate in Mr. Houck’s arrest (including forwarded email messages or CC or BCC email messages). For purposes of this Request, and unless otherwise indicated, the timeframe of the records requested herein is from May 1, 2022, to September 30, 2022; and January 1, 2023, to February 8, 2023.

Reproduced Record at 1a-2a (R.R. __) (emphasis added) (emphasis in original omitted). On November 27, 2023, following a 30-day extension, the State Police denied the Request, stating that its search found no records responsive to Item Nos.

2 1-6 of the Request. It denied Item No. 7 of the Request for the stated reason that it was not sufficiently specific, as required under Section 703 of the RTKL.2 The State Police provided a verification from its open records officer that attested to the statements in the denial. On December 18, 2023, Requester appealed to the OOR, arguing that Item No. 7 of the Request was sufficiently specific. The OOR invited both parties to supplement the record. On December 29, 2023, the State Police declined, stating it would rely upon its response and attestation. Requester likewise did not supplement the record. On January 12, 2024, the OOR denied Requester’s appeal and determined that Item No. 7 failed to satisfy the three-part test for sufficient specificity set forth in Pennsylvania Department of Education v. Pittsburgh Post- Gazette, 119 A.3d 1121, 1124 (Pa. Cmwlth. 2015) (Pittsburgh Post-Gazette), which examines the subject matter of the request; the scope of the documents sought; and the time frame for which the records are sought. The OOR acknowledged that keywords may be used to identify the subject matter of a request. Nevertheless, the OOR found that the keywords in Item

2 65 P.S. §67.703. It states as follows: A written request for access to records may be submitted in person, by mail, by e- mail, by facsimile or, to the extent provided by agency rules, by any other electronic means. A written request must be addressed to the open-records officer designated pursuant to section 502. Employees of an agency shall be directed to forward requests for records to the open-records officer. A written request should identify or describe the records sought with sufficient specificity to enable the agency to ascertain which records are being requested and shall include the name and address to which the agency should address its response. A written request need not include any explanation of the requester’s reason for requesting or intended use of the records unless otherwise required by law. 65 P.S. §67.703 (emphasis added). 3 No. 7 of the Request, such as “Catholic” and “Christian,” were too general because they were likely to appear throughout the State Police’s emails “in a vast array of context.” OOR Final Determination at 5-6; R.R. 24a-25a. While Item Nos. 1-6 of the Request showed “a shared concern with Mr. Houck’s arrest,” Item No. 7 was not “included in any of the refinements of scope in the Request’s later paragraph, and the Request specifies that the scope is to include the entirety of the [State Police], including all employees and agents.” OOR Final Determination at 6; R.R. 25a. The OOR was also critical of the “lengthy timeframe” of the Request. OOR Final Determination at 5; R.R. 24a. Viewing “the structure of the Request” as a whole, the OOR concluded that Item No. 7 did not pass the Pittsburgh Post-Gazette specificity test. OOR Final Determination at 6; R.R. 25a. Requester petitioned for this Court’s review. Appeal On appeal, Requester argues that the OOR erred in its application of the three-part test in Pittsburgh Post-Gazette, 119 A.3d at 1124. Item No. 7 of the Request contained a subject matter in its specific list of search items; identified a discrete group of documents by type, i.e., email communications; and included a finite time frame of six months. As such, the Request was sufficiently specific under Section 703 of the RTKL. In support, Requester explains that a RTKL request need not identify a particular agency transaction or activity; it can identify the subject matter of the request with keyword search terms. Requester argues that his keyword search terms identified the subject matter because the search terms are “closely related” to each other, and, read in conjunction with Item Nos. 1-6, they relate to Mark Houck, his arrest by the State Police, and his organization “Kings Men.” Requester Brief at 13;

4 Reply Brief at 3. Requester also argues that because the request is limited to emails sent over a period of six-months, it satisfies the finite time requirement of Pittsburgh Post-Gazette. The State Police responds that the OOR did not err. The keywords in Item No. 7 did not identify a subject matter. Unlike Item Nos. 1-6, which specified the potential records custodians and agency transaction, i.e., the arrest of Mark Houck, Item No. 7 of the Request lacked the “hallmarks of context.” State Police Brief at 13. Absent context for the 14 keywords, the Request lacked a meaningful subject matter, making it impossible for the State Police to respond to the Request. Applicable Legal Principles In appeals of OOR decisions, this Court is the ultimate factfinder. Section 1301 of the RTKL, 65 P.S. §67.1301.

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E. Greim v. PSP (OOR), Counsel Stack Legal Research, https://law.counselstack.com/opinion/e-greim-v-psp-oor-pacommwct-2025.