Glasgow School District v. Howard County Coroner

CourtMissouri Court of Appeals
DecidedSeptember 21, 2021
DocketWD83990
StatusPublished

This text of Glasgow School District v. Howard County Coroner (Glasgow School District v. Howard County Coroner) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Glasgow School District v. Howard County Coroner, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Western District

 GLASGOW SCHOOL DISTRICT,   Respondent,  WD83990 v.  OPINION FILED:  HOWARD COUNTY CORONER,  SEPTEMBER 21, 2021  Appellant.   

Appeal from the Circuit Court of Howard County, Missouri The Honorable Scott Hayes, Judge

Before Division One: Lisa White Hardwick, Presiding Judge, Alok Ahuja, Judge, Anthony Rex Gabbert, Judge

The Howard County Coroner (“Coroner’s Office”) appeals the judgment of the Howard

County Circuit Court finding that Coroner’s Office violated the Sunshine Law and awarding a civil

fine and attorney’s fees to the plaintiff Glasgow School District (“School District”). In four points

on appeal, Coroner’s Office claims the trial court erred in finding a violation of the Sunshine Law,

finding that the violation was purposeful, and in awarding attorney’s fees. The judgment is

affirmed in part, reversed in part, and remanded.

Facts

On December 21, 2016, seventeen year-old K.S. committed suicide. On January 31, 2017,

Coroner’s Office held a coroner’s inquest regarding the death of K.S. Coroner’s Office held the

inquest into K.S.’s death even though it had already determined the physical cause of death for K.S. and submitted a death certificate for K.S. The purpose of the inquest was to amend K.S.’s

death certificate with the inquest jury’s findings.

Coroner’s Office heard that K.S. had been bullied at school. The coroner (“Coroner”)

chose to hold the inquest into K.S.’s suicide because he did not want to be responsible for letting

another child die. Coroner hoped that holding the inquest might prevent another child’s death. In

an interview with the television network HBO in 2017, Coroner stated, “this is bullying that’s so

bad that a kind, 17 year old boy, took his life. We need to do something to prevent that from

happening again.”

The inquest was announced through a news release published in the Fayette Newspaper on

January 10, 2017. Coroner’s Office empaneled six jurors and conducted the inquest in an open

manner before the general public. Numerous members of the community and local media attended

the inquest.

The inquest was at the sole discretion of Coroner’s Office. Coroner’s Office was involved

with determining which exhibits to present to the jury and the members of the public in attendance.

Coroner’s Office also determined what witnesses to call at the public hearing.

Coroner’s Office presented all of the information and testimony at the inquest in front of

the viewing public. There was no limiting instruction by anyone as to the use or dissemination of

the evidence or testimony presented at the public inquest. It was transcribed in its entirety. The

inquest concluded that K.S. died from a felony and identified an individual as the perpetrator. It

also concluded School District was negligent. The person identified in the inquest as the

responsible party was charged criminally, and those charges were pending from January 31, 2017

through July 12, 2019.

2 On February 2, 2017, School District requested a copy of the inquest transcript from

Coroner’s Office. It hoped to clear its name with respect to the bullying that occurred at school.

On February 17, 2017, Sherry Shives requested a copy of the inquest transcript from Coroner’s

Office. Shives’ son had been identified as one of K.S.’s bullies, and Shives wanted to clear his

name.

On February 17, 2017, Coroner’s Office called the Attorney General’s Office and inquired

whether the transcript was an open record under the Sunshine Law. Coroner’s Office was advised

it may be an open record and to contact local counsel. On February 21, 2017, Coroner’s Office

spoke with April Wilson, the special prosecuting attorney assigned to K.S.’s case, about whether

the transcript was an open record. Wilson advised she believed it was closed as an investigative

report but would confirm that and let School District know.

On February 23, 2017, Coroner’s Office provided Shives a copy of the inquest transcript,

free of charge. On February 23, 2017, Coroner’s Office provided K.S.’s family a copy of the

inquest transcript, free of charge.1 Coroner’s Office did not provide a copy of the inquest transcript

to School District on that date.

On February 24, 2017, School District made another request for the inquest transcript and

exhibits. School District was informed it would have to pay for a copy of the inquest transcript.

Coroner’s Office did not provide a copy of the transcript to School District.

On February 25, 2017, Wilson told Coroner’s son2 via text message that she believed that,

if Coroner’s Office sent her a copy of the inquest transcript, that it would become investigative

1 Section 610.100.4 provides that K.S.’s family may obtain any closed record for purposes of investigation of any civil claim or defense. 2 Wilson testified that she knew Coroner’s son, an attorney, because she had previously worked with him.

3 and could not be released. On March 2, 2017, Wilson advised School District she believed the

inquest transcript and exhibits were closed. Also on March 2, 2017, Coroner’s Office advised

School District that the inquest transcript and exhibits were closed as investigative records and

would not be provided to School District.

On March 2, 2017, School District made another request to Coroner’s Office for the inquest

transcript and exhibits. On March 3, 2017, Coroner had his son email a copy of the inquest

transcript to Wilson. Coroner’s Office did not provide the transcript and exhibits to School

District. On March 9, 2017, School District sent correspondence to Coroner’s Officer following

up on the March 2, 2017 request. It attached an Attorney General Opinion Letter3 from 1979 that

stated in relevant part:

It is our view that the exception specified in §610.025 are not applicable, and that the coroner’s jury, constitutes a “public governmental body,” that the coroner’s records, unless specifically designated otherwise, are public records and that the inquest conducted by the coroner pursuant to Chapter 58 is a “public meeting” within the provision of the Sunshine Law. … It is likewise our view that the county coroner does not have the authority the refuse to grant access to materials which may be presented at an inquest.

After reviewing this letter, Coroner’s Office still chose not to provide a copy of the inquest

transcript or exhibits to School District.

On March 13, 2017, Coroner’s Office sent a letter to School District’s counsel advising

that the requested records were a part of Wilson’s criminal investigation, were not open records,

and could not be released until Wilson released them. On March 23, 2017, School District filed

the underlying lawsuit requesting access to the inquest transcript and exhibits.

3 “An Attorney General's Opinion is not binding on this court.” Smith v. Sheriff, 982 S.W.2d 775, 779 (Mo. App. E.D. 1998). The 1979 letter predated section 610.100 and relied on a version of section 610.025 which has since been repealed.

4 On June 7, 2017, the television network HBO published a video interview with Coroner.

In the interview, Coroner discussed the inquest matter. Video footage from the inquest was aired.

The contents of the suicide notes4 K.S. left were divulged. Some of the typed pages of the

transcript of the inquest testimony were also shown on screen. Coroner knew his interview would

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Glasgow School District v. Howard County Coroner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/glasgow-school-district-v-howard-county-coroner-moctapp-2021.