Manns v. City of Charleston Police Department

550 S.E.2d 598, 209 W. Va. 620
CourtWest Virginia Supreme Court
DecidedJuly 24, 2001
Docket28743
StatusPublished
Cited by14 cases

This text of 550 S.E.2d 598 (Manns v. City of Charleston Police Department) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Manns v. City of Charleston Police Department, 550 S.E.2d 598, 209 W. Va. 620 (W. Va. 2001).

Opinions

PER CURIAM:

This case is before this Court upon appeal of a declaratory and injunctive relief order entered by the Circuit Court of Kanawha County on February 24, 2000, ordering the appellants and defendants below, the City of Charleston Police Department and Jerry Riffe, in his official capacity as Chief of Po[622]*622lice1 (hereinafter “appellants”), to disclose various police records including internal investigation documents pursuant to a Freedom of Information Act request by the appel-lee and plaintiff below, Laura Manns. In this appeal, the appellants contend that the circuit court erroneously concluded that the requested documents were not exempt from disclosure pursuant to W.Va.Code § 29B-1-4 (1977).

This Court has before it, the petition for appeal, the entire record, and the briefs and argument of counsel.2 For the reasons set forth below, the final order of the circuit court is reversed.

I.

The appellee was arrested on November 11, 1996, after she refused to pay a bus fare at the KRT Transit Mall in Charleston, West Virginia. The appellee was charged with several offenses including battery on a police officer and resisting arrest. Thereafter, the appellee asserted that police officer Cathy Smith used excessive force in carrying out her arrest. Accordingly, the appellants initiated an internal investigation. In addition, the appellants asked the Federal Bureau, of Investigation (hereinafter “FBI”) to conduct its own, independent investigation. Both the appellants and the FBI exonerated Officer Smith.

Subsequently, the appellee retained counsel to represent her in a federal civil rights elaim and to defend her against the criminal charges.3 As part of her pre-suit investigation, the appellee requested that the appellants provide various records and information including internal investigation documents to her pursuant to the Freedom of Information Act, W.Va.Code § 29B-1-1 to -7 (1977) (hereinafter “FOIA”). The appellants produced about half of the records the appellee requested and objected to supplying the remaining documents and information. Consequently, the appellee filed suit in the Circuit Court of Kanawha County on February 5, 1997, and requested the circuit court to compel disclosure of the remaining documents despite the appellants’ objections. After the matter was briefed and argued, the circuit court ruled that the appellee was entitled to a mandatory injunction compelling the production of the records that she requested, except the limited documents to which there is a valid internal memoranda claim.

II.

We begin our analysis of this ease by setting forth our standard of review. As discussed above, this case requires an interpretation of the FOIA. In Syllabus Point 1 of Chrystal R.M. v. Charlie A.L., 194 W.Va. 138, 459 S.E.2d 415 (1995), this Court held that “[wjhere the issue on an appeal from the circuit court is clearly a question of law or involving an interpretation of a statute, we apply a de novo standard of review.” With this standard in mind, we now consider the parties’ arguments.

This appeal primarily concerns the appel-lee’s FOIA request for the following information:

a. The names of every officer against whom a complaint has been made, or who the Charleston Police Department has investigated on their own, regarding that officer’s behavior while in the course of employment or otherwise;
b. The names of every officer against whom a civil or criminal complaint has been filed regarding their behavior while in the course of employment or otherwise;
c. In respect to subpart “a” and “b” please state the outcome of said complaints or investigations.

The appellee has also requested information regarding the officer who arrested her. Specifically, the appellee has asked whether any complaints have been filed against the officer; the substance of those complaints; and [623]*623the disposition of those complaints. The ap-pellee has further sought a copy of or access to the appellants’ records regarding the investigation of the appellee’s arrest.

This Court recently addressed a similar request for police records in the context of discovery during civil litigation. In Maclay v. Jones, 208 W.Va. 569, 542 S.E.2d 83 (2000), the plaintiffs, Donald and Karen Maclay, through a notice of deposition and subpoena duces tecum, requested records relative to an internal affairs investigation of complaints filed against a state trooper as well as the trooper’s personnel file. In response, the defendant West Virginia State Police sought a protective order claiming that statutory and common law privileges prohibited disclosure of the requested information. Eventually, the circuit court certified questions to this Court for a determination of whether this type of information was subject to disclosure during civil litigation.

In Syllabus Point 2 of Maclay, this Court determined that:

The provisions of this state’s Freedom of Information Act, West Virginia Code §§ 29B-1-1 to -7 (1998), which address confidentiality as to the public generally, were not intended to shield law enforcement investigatory materials from a legitimate discovery request when such information is otherwise subject to discovery in the course of civil proceedings.

Thus, this Court held that:

Records and information compiled by an internal affairs division of a police department are subject to discovery in civil litigation arising out of alleged police misconduct if, upon an in camera inspection, the trial court determines that the requesting party’s need for the material outweighs the public interest in maintaining the confidentiality of such information.

Syllabus Point 3, Maclay. However, we also stated that:

Before a circuit court is required to engage in an in camera inspection of records and information compiled by an internal affairs division of a police department to make a determination regarding the production of such documents through discovery, the party opposing disclosure must first make a substantial threshold showing that specific harms are likely to result from the disclosure of the requested materials.

Syllabus Point 4, Maclay. While our decision in Maclay is certainly instructive, it is not dispositive of the issues now before us. In this case, the police records were sought through a FOIA request and at that time, there was no ongoing litigation.4 As we noted in Maclay, the “FOIA provisions which address the confidentiality of records and their availability to the general public are aimed at protecting interests distinct from those at issue when records are requested in conjunction with a civil rights action.” 208 W.Va. at 574, 542 S.E.2d at 88 (citations omitted). Thus, we must determine whether the documents requested by the appellee are exempt from disclosure pursuant to W.Va. Code § 29B-1-4 as asserted by the appellants.

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Manns v. City of Charleston Police Department
550 S.E.2d 598 (West Virginia Supreme Court, 2001)

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Bluebook (online)
550 S.E.2d 598, 209 W. Va. 620, Counsel Stack Legal Research, https://law.counselstack.com/opinion/manns-v-city-of-charleston-police-department-wva-2001.