M. Bonner v. DCED (OOR)

CourtCommonwealth Court of Pennsylvania
DecidedMay 8, 2026
Docket1636 C.D. 2024
StatusUnpublished
AuthorWolf

This text of M. Bonner v. DCED (OOR) (M. Bonner v. DCED (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
M. Bonner v. DCED (OOR), (Pa. Ct. App. 2026).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Michael Bonner, : Petitioner : : v. : No. 1636 C.D. 2024 : Department of Community : and Economic Development : (Office of Open Records), : Respondent : Argued: April 13, 2026

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE MATTHEW S. WOLF, Judge HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE WOLF FILED: May 8, 2026

Michael Bonner (Requester) petitions this Court for review of a November 4, 2024 Final Determination of the Office of Open Records (OOR). The Final Determination denied Requester’s appeal from the Department of Community and Economic Development’s (Department) denial of a request for records on the basis that the records sought do not document a transaction or activity of the Department, and thus do not constitute “records” under Section 102 of the Right-to- Know Law (RTKL).1 For the reasons that follow, we affirm.

1 Act of February 14, 2008, P.L. 6, 65 P.S. § 67.102. Background On July 5, 2024, Requester submitted a RTKL request (Request) to the Receiver for the City of Chester (Receiver),2 as an employee of the Department,3 seeking the following:

1. The City of Chester’s redacted codification of ordinances, including any and all record books and compilations of ordinances recorded by the City’s clerk, or redacted copies of same.

2. The redacted index(es) for the City of Chester’s redacted codification of ordinances, including the index(es) for any and all record books and compilations of ordinances recorded by the City’s clerk, or a redacted copy of same.

3. The City of Chester’s redacted resolutions, including any and all record books and compilations of resolutions recorded by the City’s clerk, or redacted copies of same.

4. The redacted index(es) for the City of Chester’s redacted resolutions, including the index(es) for any and all record books and compilations of resolutions recorded by the City’s clerk, or redacted copies of same.

2 Vijay Kapoor presently serves as the Receiver for the City of Chester, a financially distressed municipality under the Municipalities Financial Recovery Act, Act of July 10, 1987, P.L. 246, No. 47, as amended, 53 P.S. §§ 11701.101-11701.712, commonly referred to as “Act 47”. 3 The Request explained:

These requests are being sent to the Agency Open Records Officer for the Pennsylvania Department of Community and Economic Development (“[Department]”) based on the attached business card of the Receiver for the City of Chester (Attachment “C” to the enclosed Standard Right-to-Know Law Request Form) indicating that the Receiver is associated with the [Department].

Reproduced Record (R.R.) 16a.

2 5. The City of Chester’s redacted rules and/or regulations applicable to any commercial or non-profit entity operating in the City, including any and all record books and compilations of rules and/or regulations applicable to any commercial or non-profit entity operating in the City of Chester, or copies of same.

6. The redacted index(es) for the City of Chester’s redacted rules and/or regulations applicable to any commercial or non-profit entity operating in the City, or redacted copies of same.

7. The City of Chester’s redacted Home Rule Charter, or a redacted copy of same.

8. To the extent not included in the above, the redacted codification of ordinances titled “The General Laws of the City of Chester” pursuant to § 11.4-406 of the City of Chester’s Home Rule Charter, or a redacted copy of same.

9. To the extent not included in the above, the City of Chester’s redacted Code of Ordinances or a redacted copy of same.

10. To the extent not included in the above, the City of Chester’s redacted Administrative Code or a redacted copy of same.

11. To the extent not included in the above, all redacted ordinances, resolutions, rules, regulations, and/or other official actions of the City of Chester and/or its Council having the force and effect of law that are applicable to any commercial or non-profit entity operating in the City of Chester, or redacted copies of same. Reproduced Record (R.R.) 14a-17a (redactions in original).4 The Department invoked a thirty-day extension, 65 P.S. § 67.902(b). On August 11, 2024, the

4 The Request included the redactions. Requester explained that the identical unredacted request was sent to the Receiver on May 30, 2024, but was denied “because it mandates that the Department conducts legal research to determine whether the conditions established in the request (Footnote continued on next page…)

3 Department denied the Request on the basis that it lacked sufficient specificity under Section 703 of the RTKL, 65 P.S. § 67.703, because it required the Department to perform legal research. R.R. 6a-7a. Requester appealed the Department’s denial to the OOR. The OOR invited the parties to submit supplemental evidence and file position statements. R.R. 48a. Requester filed a position statement arguing his appeal should be granted for three principal reasons. First, he argued that contrary to the Department’s assertion, no legal research is required to produce records responsive to the Request. He maintained that the Request unambiguously identifies documents and the Department must merely locate them, not conduct any legal research or analysis thereon. Second, he argued the Request seeks “records” of the Department as defined in Section 102 of the RTKL, 65 P.S. § 67.102, because “[c]onsidering and modifying the City’s ordinances and other laws are activities which are central to the governmental functions of the [Department] and Receiver pursuant to statute.” R.R. 87a. Third, Requester argued that none of the items in the Request are barred by any state or federal law, regulation, judicial order, privilege, or exception set forth in Section 708 of the RTKL. For these reasons, Requester asked the OOR to grant his appeal in full and direct disclosure of all responsive records. The Department supplemented the record with an attestation of Eileen Quinn, the Department’s Open Records Officer (Quinn Attestation). R.R. 81a-85a. Therein, Ms. Quinn attested that upon receipt of the Request, she submitted it to the Department’s legal counsel for review. Id. at 82a. The attestation explains:

have been fulfilled in order to respond. . . .” R.R. 16a, 19a. Requester stated that “[i]n resubmitting the request for documents, I have redacted all of what [the Department] classified as imposing ‘conditions.’” Id. at 16a.

4 4. From that review, the Department determined that each part of the Request requires the Department to review City of Chester ordinances, statutes, rules, regulations, administrative code, official actions, and/or Home Rule Charter to develop legal opinions as to whether such ordinances, statutes, rules, regulations, administrative code, official actions, and/or Home Rule Charter are currently in force for (and also as to specific codifications for parts 1 and 2) and represent the applicable legal authority for the City and have not been discarded or overruled by the City of Chester in lieu of updated or revised ordinances, statutes, rules, regulations, administrative code, official actions, and/or Home Rule Charters. See Ex. “A.”

5. Additionally, each part of the Request offers no limiting timeframe as to the records sought, further evidencing the Request’s lack of sufficient specificity and further necessitating an opinion be developed as to the legal significance of the records to be reviewed. 65 P.S. § 67.703; Askew v. Pa. Off. of the Governor, 65 A.3d 989, 993-94 (Pa. [Cmwlth.] 2013).

6.

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M. Bonner v. DCED (OOR), Counsel Stack Legal Research, https://law.counselstack.com/opinion/m-bonner-v-dced-oor-pacommwct-2026.