Hawes v. Cumberland County Sheriff's Office

CourtSuperior Court of Maine
DecidedJanuary 3, 2022
DocketCUMap-19-39
StatusUnpublished

This text of Hawes v. Cumberland County Sheriff's Office (Hawes v. Cumberland County Sheriff's Office) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hawes v. Cumberland County Sheriff's Office, (Me. Super. Ct. 2022).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION DOCKET NO. AP-19-39

SUSAN HAWES,

Plaintiff V. ORDER

CUMBERLAND COUNTY SHERIFF'S OFFICE,

Defendant

In this case, much delayed by the pandemic, the court held a hearing on November 18,

2021 to address Counts 4, 5, and 6 of plaintiff Susan Hawes's second amended complaint. 1 After

the hearing the parties were allowed until December 6 to submit any additional legal argument.

Ms. Hawes submitted a memorandum of law on December 6. Counsel for the Cumberland County

Sheriffs Office did not submit an additional memorandum.

Count Four

The evidence offered at the hearing with respect to Count 4 demonstrated that the records

that were the focus of the request by Ms. Hawes - reflecting the amount of forced overtime - are

kept by the union rather than by the Sheriffs Office or by the county. 2 Accordingly, Ms. Hawes

is not entitled to relief on Count 4.

1 Counts I, 2, and 3 of Ms. Hawes's complaint have previously been addressed.

2 As Ms. Hawes noted at the hearing, it would have saved eve1yone time if that had been explained to Ms.

Hawes at an earlier point. Counts Five and Six

(a) Subject matter jurisdiction

At the outset of the hearing, counsel for defendant raised an objection to Counts 5 and 6

on grounds on subject matter jurisdiction. The court had not previously granted Ms. Hawes leave

to amend to assert Counts 5 and 6. The defendant did not initially object to the addition of the

additional counts but instead simply filed a response to the second amended complaint. It did,

however, raise subject matter jurisdiction as an affirmative defense and renewed that defense at

the hearing.

Under the circumstances of this case, the court concludes that subject matter jurisdiction

exists. Ms. Hawes filed her second amended complaint on April 14, 2021. Count 5 related to an

FOAA request she had submitted on March 19. Count 6 related to an FOAA request she had

submitted on March 15. The Sheriffs Office did not deny her requests. It provided records in

response to those requests on April 1 and 2 - although Ms. Hawes contends the records provided

did not comply with the FOAA. The Sheriffs office contends it complied with her requests and

with the statute.

The FOAA provides that a person aggrieved by an agency's refusal, denial, or failure to

allow inspection and copying may appeal within 30 calendar days. 1 M.R.S § 409(1). In a case

where records are provided but the requester contends that the response failed to comply with the

FOAA, the court would interpret the 30 days as running from the allegedly non-compliant

response. In any event, the second amended complaint in this case was filed within 30 calendar

days of Ms. Hawes's March 15 and 19 requests and within 14 days of the response that Ms. Hawes

contends failed to comply with the FOAA. This was timely under 1 M.R.S. § 409(1).

2 In the court's view, the 30 day deadline goes to timeliness and a failure to meet that

deadline does not deprive the court of subject matter jurisdiction. Even if that is incorrect, Ms. - -- --- - ---- --- ----

Hawes met the 30 day deadline. If she had filed a new FOAA complaint on April 14, 2021, that

would have been timely. Where this action was already pending, the issue reduces to whether Ms.

Hawes was required to pay a second filing fee to file a new complaint. 3 Freedom of Access

litigation should not turn on such technicalities, particularly in light of the statutory provision that

FOAA appeals may be advanced on the docket and receive priority when the court determines that

the interests of justice so require. Moreover, leave to amend shall be freely given when justice so

requires. The court will allow the amendment to add Counts 5 and 6 and will consider those counts.

(b) Redaction of payroll codes

With respect to the requests that are the subject of Counts 5 and 6, the information sought

is contained in data files maintained by Cumberland County. The Sheriffs Office does not itself

maintain records with the information requested, and the records produced to Ms. Hawes therefore

came from the County.

On Count 5 Ms. Hawes received records with the pay codes redacted. The basis for this

redaction is that disclosure of pay codes might reveal the payment of sick pay. The only

justification for such a redaction, as far as the court is aware, would be 30-A M.R.S. §

3 Another issue, lurking in the background, is whether, if Ms. Hawes had missed the 30-day deadline, she would have been precluded from refiling the same request and bringing a new appeal. Counsel for tbe Sheriff's Office suggested at tbe hearing that she would have been precluded. The comi does not need to reach this issue but is inclined to disagree. To preclude a second request for the same records if the 30 day deadline is missed would infuse the Freedom of Access statute with a trap for the unwary. This is particulai·ly true in a case where a requester receives records but discovers potential omissions in the agency's response after the fact. Moreover, if this were the rule, a requester could simply refra1Ue the request more broadly or in different language.

3 503(1)(B)(l), which exempts "county records containing ... [m]edical information of any kind,

including information pertaining to the diagnosis or treatment of mental or emotional disorders." ------ ------ ---

The question is whether the fact that an employee received sick pay constitutes "medical

information of any kind." Following the principle that FOAA exemptions shall be strictly

construed, see, e.g., Citizens Communication Co. v. Attorney General, 2007 ME 114 ,r 9, 931 A.2d

503, the court concludes that the exemption for medical information should be limited to any

information relating to symptoms, illnesses, diagnoses, and treatment including, as the statute

expressly provides, any information relating to mental or emotional disorders. Just because an

employee receives sick pay, however, does not constitute confidential medical information. This

is consistent with precedent in other states. See Clymer v. City of Cedar Rapids, 601 N. W. 2d 42,

46, 48 (Iowa 1999) and cases cited therein.

(c) Disabled Spreadsheets

In the records produced that are the subject of Counts 5 and 6, the Sheriff's Office produced

records in spreadsheet form that were "locked." This was done after the data requested was

obtained from the county's data file and placed on spreadsheets. The Sheriff's Office thereafter

locked the spreadsheets before producing them to Ms. Hawes. If the spreadsheets had been

produced in an unlocked form, Ms. Hawes could have used the spreadsheets, for example, to total

various columns and could have cut and pasted data from the spreadsheets. In locked form, she

may have been able to reorganize the data (e.g., from lowest to highest) to a very limited extent

but she could not have performed any other operations or functions.

The defense witnesses at the hearing testified that they had just begun locking spreadsheets

in early 2021 and that this was done for security reasons. They stated that they would lock

4 spreadsheets in response to other requests, but it did not appear that any spreadsheets other than

the ones requested by Ms. Hawes had yet been locked. ----

Whether locldng a spreadsheet complies with the FOAA requires interpretation of two

provisions in the statute.

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Related

Kay v. Ehrler
499 U.S. 432 (Supreme Court, 1991)
Citizens Communications Co. v. Attorney General
2007 ME 114 (Supreme Judicial Court of Maine, 2007)
Clymer v. City of Cedar Rapids
601 N.W.2d 42 (Supreme Court of Iowa, 1999)
Marcel Dubois v. Department of Agriculture, Conservation and Forestry
2018 ME 68 (Supreme Judicial Court of Maine, 2018)
Dubois v. Dep't of Agric., Conservation & Forestry
185 A.3d 743 (Supreme Judicial Court of Maine, 2018)

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Hawes v. Cumberland County Sheriff's Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hawes-v-cumberland-county-sheriffs-office-mesuperct-2022.