MaineToday Media, Inc. v. Maine State Police

CourtSuperior Court of Maine
DecidedSeptember 12, 2014
DocketKENap-14-41
StatusUnpublished

This text of MaineToday Media, Inc. v. Maine State Police (MaineToday Media, Inc. v. Maine State Police) 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
MaineToday Media, Inc. v. Maine State Police, (Me. Super. Ct. 2014).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, SS. CIVIL ACTION DOCKET NO. AP-14-41

MAINETODA Y MEDIA, INC.,

Plaintiff

v. DECISION ON APPEAL

MAINE STATE POLICE,

Defendant

In 2013, a police officer with the Hallowell Police Department reported a sexual

assault which she alleged was committed by the Chief of the Hallowell Police

Department. As a result, and in accordance with standard procedure, an investigation

was conducted by the Maine State Police. This investigation was completed in October

of 2013. In spite of repeated demands by the Plaintiff, the Maine State Police have

refused to disclose the contents of their investigation. The District Attorney has not

initiated prosecution of the accused based upon the officer's complaint.

Counsel for both the accusing officer and the accused Chief have made a number

of public statements and disclosures with regard to the circumstances. The disclosures

have appeared in the newspapers which are represented by the Plaintiff. The Plaintiff,

which represents the Kennebec Journal, Portland Press Herald, and Morning Sentinel,

appeals the investigative and prosecuting agency's refusal to publicly disclose, filed

pursuant to M.R. Civ. P. 80C, and 1 M.R.S. § 409(1). Title 1 M.R.S. §§ 401-414 is the Freedom of Access Act (FOAA) in Maine law.

This requires that records of public proceedings be open to public inspection. It requires

that the body of law under the FOAA be liberally construed "to promote its underlying

purposes and policies as contained in the declaration of legislative intent." 1 M.R.S. §

401. It states that "public records" means any written or electronic data in the possession

or custody of an agency or public official that has been received or prepared for use in

connection with the transaction of public or governmental business except records that

have been designated confidential by statute. 1 M.R.S. § 402(3). These records may also

include public criminal history records as defined in 16 M.R.S. § 703(8). The public has

a right to inspect and copy any public records during reasonable office hours. A refusal

by an agency having custody and control of a public record must be by written notice of

denial, stating the reason for the denial. 1 M.R.S. § 408-A. Any person aggrieved by a

refusal or denial to inspect the public records under section 408-A may appeal the refusal

to the Superior Court, which shall hold a de novo proceeding. 1 M.R.S. § 409(1).

Dissemination of criminal history record information by a Maine criminal justice

agency is governed by the Criminal History Record Information Act, 16 M.R.S. §§ 701-

710. It differentiates between public criminal history record information and confidential

criminal history record information. 1 M.R.S. § 702. Specifically, confidential criminal

history record information includes information disclosing that the prosecutor has elected

not to initiate or approve criminal proceedings. 16 M.R.S. § 703(2)(C). Criminal history

record information includes such information as arrests, bail, formal criminal charges,

indictments, and the like, but does not include "intelligence and investigative record

2 information as defined in § 803." 16 M.R.S. § 703(3). Confidential criminal history

record information may only be disseminated through a specific list of persons and

agencies not applicable in the present case. 16 M.R.S. § 705.

The Intelligence and Investigative Record Information Act, 16 M.R.S. §§ 801-809,

defines "intelligence and investigative record information" as that information "collected

by or prepared by or at the direction of a criminal justice agency or kept in the custody of

a criminal justice agency while performing the administration of criminal justice[.]" 16

M.R.S. § 803(7). Among other things, it includes information of record concerning

investigative techniques and procedures. It does not include criminal history record

information as defined in 16 M.R.S. § 703(3). !d. Other than with specific exception, a

record that contains intelligence and investigative record information is confidential and

may not be disseminated by a criminal justice agency to any person if there is a

reasonable possibility public release or inspection of the record will interfere with law

enforcement proceedings or constitute an unwarranted invasion of personal privacy. 16

M.R.S. § 804(1), (3). The exceptions are listed in 16 M.R.S. §§ 805 and 806, but subject

to "reasonable limitations imposed by a Maine criminal justice agency to protect against

the harms described in section 804 .... " 16 M.R.S. § 806. It is a criminal offense for a

person to knowingly and intentionally unlawfully disseminate confidential intelligence

and investigative record information. 16 M.R.S. § 809.

Plaintiff asserts that the investigative information in the possession of the Maine

State Police is a "public record" pursuant to 1 M.R.S. § 402(3). As such, they argue that

the public has a right to inspect and copy the public records pursuant to 1 M.R.S. §

3 408-A, as the statute should be liberally construed by 1 M.R.S. § 401. Accordingly,

Plaintiff asks the court to determine that the refusal of the Maine State Police to disclose

the results of its investigation is not for just and proper cause and enter an order of

disclosure, if necessary with appropriate redaction.

The Plaintiff argues that the amount of information regarding the details of the

incident in question as disclosed by public statements of counsel for both the officer and

the Chief has removed any expectation of privacy on the part of either party and therefore

release of the investigative information would not constitute an unwarranted invasion of

personal privacy. Further, if there is such an invasion, the public interest in disclosure of

such information outweighs any privacy concerns that might remain after the public

statements. This is particularly important in light of the fact that the accused is the Chief

of Police of a Maine city, and therefore a person occupying a highly responsible position.

The fact that position is Chief of a law enforcement agency enhances the public interest.

The Plaintiff notes the necessity of transparency in government and asserts the

importance of reviewability by the public to address any issues of the diligence of the

Maine State Police investigation or the operation of the Hallowell Police Department.

The Defendant, on the other hand, invokes the public policy as expressed in a

large number of statutory provisions which relate to the protection and privacy interest of

persons involved in criminal investigations, particularly those alleging matters of a sexual

nature. 1 To that end, the State argues that the release of the information in question

1 Title 5 M.R.S. §§ 90-B, 3360-M, 4656; 17-A M.R.S. § 1176, 1177; 24 M.R.S. § 2986; 25 M.R.S. § 7821.

4 would clearly be unwarranted in light of the privacy interests that remain in both the

accuser and the accused. It argues that the investigation report is not a public record but

instead is confidential criminal history record information. Further, the State argues that

the dissemination of the information would interfere with the operations of law

enforcement in terms of investigative technique and relationship with alleged victims of

sexual assault.

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