MaineToday Media, Inc. v. State of Maine

CourtSuperior Court of Maine
DecidedMarch 8, 2013
DocketCUMap-13-6
StatusUnpublished

This text of MaineToday Media, Inc. v. State of Maine (MaineToday Media, Inc. v. State of Maine) 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. State of Maine, (Me. Super. Ct. 2013).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss. CIVIL ACTION

~o~~~~t-~~:· ~:l];~! MAINETODA Y MEDIA, INC., Plaintiff/Appellant

v.

STATE OF MAINE, Defendant/Appellee

Pursuant to Maine Rule of Civil Procedure 80C and 1 M.R.S.A. § 409 ofthe

Freedom of Access Act, PlaintiffMaineToday Media appeals the decision of Defendant

State of Maine to deny its request for access to 911 call transcripts related to the James

Pak shooting in Biddeford on December 29, 2012.

Background

The parties submitted an agreed statement of facts. In an indictment dated

February 5, 2013, James Pak was charged with two counts of murder in connection with

the shooting deaths of Derrick Thompson, 19, and his girlfriend Ali via Welch, 18, on

December 29, 2012. He was also charged with attempted murder and elevated

aggravated assault with a firearm in connection with the shooting of Derrick's mother

Susan Johnson on the same day. Mr. Pak was the landlord of Derrick, Alivia, and Susan

at 17 -A Sokokis Road in Biddeford, where the alleged crimes took place.

On December 29, 2012, at approximately 6:07pm, prior to being shot by Mr. Pak,

Derrick called 911 concerning Mr. Pak's behavior. One or more Biddeford police

officers responded, spoke with Derrick and Mr. Pak, and left the scene.

1 At approximately 6:54 the same evening, three minutes after police officers had

left the scene and after she had been shot, Susan placed another 911 call.

At approximately 7:02pm, Armit Pak, the wife ofMr. Pak, placed a 911 call.

All three calls were recorded and transcripts exist.

On January 2, 2013, Portland Press Herald 1 reporter David Hench requested a

copy ofthe transcript ofthe 911 call placed by Derrick Thompson. The Maine State

Police and Department of Public Safety denied that request and a subsequent request to

reconsider, citing the "intelligence and investigative information" exception to the

Freedom of Access Act. 16 M.R.S.A. § 614. The Attorney General's Office indicated

via email that it concurred in that position.

On January 11,2013, counsel for MaineToday Media (MTM) made a formal

request for all 911 transcripts in connection with all active homicide investigations and

ongoing homicide prosecutions, 2 including the three calls related to Mr. Pak placed on

December 29. The Attorney General's office denied the request on the same grounds.

The State's position is that in any active homicide investigation or prosecution, 911 call

recordings and transcripts constitute "intelligence and investigative information" subject

to § 614. MTM timely appealed the denial on January 22, 2013.

Discussion

On appeal, a party aggrieved by a FOAA denial is entitled to de novo review in

the Superior Court. 1 M.R.S.A. § 409(1). Thus, the Court eschews the ordinary 80C

1 Defendant MaineToday Media publishes the Portland Press Herald. 2 However, MTM has agreed for purposes of the appeal that the State need not actually search for and identify all 911 recordings/transcripts related to all ongoing investigations and prosecutions.

2 standard of review contained in the Administrative Procedure Act. 5 M.R.S.A. §

11007(4)(C).

The transcripts in question are "public records" as defined by the Freedom of

Access Act. 1 M.R.S.A. § 402(3). The issue is whether they are specifically exempted

from disclosure by statute. § 408-A ("Except as otherwise provided by statute, a person

has the right to inspect and copy any public record ... ") (emphasis added). Two statutes

are relevant to the inquiry: (1) The Emergency Services Communications Act, 25

M.R.S.A. § 2929, and (2) the Criminal History Record Information Act, 16 M.R.S.A. §

614.

The Emergency Services Communications Act provides that "confidential

information" may not be disclosed in any manner. 25 M.R.S.A. § 2929(2). Among

other limited types of information, "confidential information" includes the "name,

address and telephone number of a caller to a public safety answering point." Id. §

2929(1)(C). Only those "portions" ofthe records containing "confidential information"

may be withheld. Jd. § 2929(3). "Other information that appears in those records and

other records, except information or records declared to be confidential under other law,

is subject to disclosure pursuant to Title 1, section 408-A." ld. (emphasis added). This

framework applies to information contained in 911 transcripts; the actual audio recording

is confidential in its entirety. ld. § 2929(4).

In this case, the bulk ofthe information contained in the three 911 calls is subject

to disclosure under 25 M.R.S.A. § 2929. Only the name, address, and telephone numbers

ofthe callers must be redacted from the three transcripts in question. 3 However, the

3 The Court has listened to the audio and read the transcripts. It does not appear that any

3 remaining information is only available to the extent it is not "declared to be confidential

under other law." !d. § 2929(3). Contrary to MTM's position that the inquiry begins and

ends with§ 2929, the Court finds that the Emergency Services Communications Act and

the Criminal History Record Information Act are independently available to limit

disclosure of otherwise public information.

Under the latter law, "[r]eports or records that contain intelligence and

investigative information and that are ... kept in the custody of ... the Department of the

Attorney General ... are confidential and may not be disseminated if there is a

reasonable possibility that public release or inspection of the records would:

(A) Interfere with law enforcement proceedings; (B) Result in public dissemination of prejudicial information concerning an accused person or concerning the prosecution's evidence that will interfere with the ability of a court to impanel an impartial jury; [or] (C) Constitute an unwarranted invasion of personal privacy.

16 M.R.S.A. § 614(1)(A)-(C).

Next, "intelligence and investigative information" is defined as follows:

information collected by criminal justice agencies or at the direction of criminal justice agencies in an effort to anticipate, prevent or monitor possible criminal activity, including operation plans of the collecting agency or another agency, or information compiled in the course of investigation of known or suspected crimes, civil violations and prospective and pending civil actions.

!d. § 611 (8) (emphasis added).

MTM argues that the term "compiled" refers only to information actually

generated by law enforcement during an investigation, not pre-existing public records

that are subsequently placed in an investigative file. The Law Court has not weighed in

on the meaning of the term "compiled." However, in interpreting the federal Freedom of

other type of"confidential information" as defined by§ 2929(l)(A)-(D) was involved.

4 Information Act, 4 the U.S. Supreme Court has interpreted the term "compiled" to include

documents gathered for law enforcement purposes that were originally generated for

some unrelated reason. John Doe Agency & John Doe Gov 't Agency v. John Doe Corp.,

493 U.S. 146, 155 (1989). The Court reasoned that the ordinary meaning of a

compilation - "something composed of materials collected and assembled from various

Free access — add to your briefcase to read the full text and ask questions with AI

Related

John Doe Agency v. John Doe Corp.
493 U.S. 146 (Supreme Court, 1989)
State v. Johnston
1 Thompson 19 (Tennessee Supreme Court, 1847)

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