Media General Operations, Inc. D/B/A Wsav-Tv v. Al St. Lawrence, Sheriff of Chatham County, Georgia

CourtCourt of Appeals of Georgia
DecidedJune 15, 2016
DocketA16A0280
StatusPublished

This text of Media General Operations, Inc. D/B/A Wsav-Tv v. Al St. Lawrence, Sheriff of Chatham County, Georgia (Media General Operations, Inc. D/B/A Wsav-Tv v. Al St. Lawrence, Sheriff of Chatham County, Georgia) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Media General Operations, Inc. D/B/A Wsav-Tv v. Al St. Lawrence, Sheriff of Chatham County, Georgia, (Ga. Ct. App. 2016).

Opinion

FOURTH DIVISION ELLINGTON, P. J., BRANCH and MERCIER, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

June 15, 2016

In the Court of Appeals of Georgia A16A0280. MEDIA GENERAL OPERATIONS, INC. v. ST. LAWRENCE et al.

MERCIER, Judge.

This appeal is from the trial court’s judgment declaring that the sheriff and

district attorney of Chatham County are not required to release to Media General

Operations, Inc. d/b/a WSAV-TV certain records under the Open Records Act,

because the records sought come within the “pending prosecution” exemption to

disclosure. We agree and affirm the trial court’s judgment.

On January 1, 2015, Matthew Ajibade was arrested and taken to the Chatham

County Detention Center. Ajibade died at the detention center on January 1, 2015 or

January 2, 2015, while he was in the custody of the Chatham County Sheriff’s Office

(“CCSO”). On January 2, 2015, CCSO personnel phoned the Georgia Bureau of

Investigation (GBI), requesting an investigation into Ajibade’s death; the GBI began

its investigation that day. That same date, the Internal Affairs Division of the CCSO

(“IAD”) began its own investigations into possible policy violations by CCSO

employees in connection with the death. In all, there were three IAD investigations

into Ajibade’s death. The IAD interviewed all persons involved in the incident, and

the CCSO planned to “review, again, the actions of other employees that may be on

the periphery of this to determine if we’re going to take additional disciplinary

action.” The IAD investigations revealed criminal activity, which activity the CCSO

referred to the district attorney for possible prosecution. In May 2015, after the GBI

and the IAD investigations had concluded, the CCSO fired nine sheriff’s deputies for

their roles in Ajibade’s death.

In June 2015, the district attorney presented a bill of indictment against two of

the fired deputies and a private employee who had worked as a nurse at the detention

center. The three individuals were indicted on charges that included involuntary

manslaughter, aggravated assault, cruelty to an inmate, falsifying records, and making

false statements to a GBI agent.

2 In about March and April 2015, Media General Operations, Inc. (“Media

General”) submitted to the CCSO requests pursuant to the Open Records Act (OCGA

§ 50-18-70 et seq.) for records pertaining to Ajibade, including video footage,

incident or arrest reports, and IAD investigation reports. In response, the CCSO

acknowledged that cameras it owned and operated had captured images of Ajibade

on the relevant dates, that the CCSO maintained and prepared the images as part of

its functions, and that it acted as custodian of the images. However, the CCSO refused

to provide the requested video footage, asserting that the footage was exempt under

OCGA § 50-18-72 (a) (4) because the footage was in the possession of the district

attorney for “use in an on-going criminal investigation.” The CCSO also refused to

release the IAD investigation reports, stating that those records were exempt under

the same statutory subsection (OCGA § 50-18-72 (a) (4)) because they had been

provided to the district attorney. (The CCSO did not produce initial incident or arrest

reports, stating that no such reports existed.) Media General renewed its request for

the video footage and IAD reports, asserting that the exemption at issue does not

apply to records in the possession of an agency that is the subject of the pending

investigation or prosecution (OCGA § 50-18-72 (a) (4), infra).

3 In May 2015, Al St. Lawrence, in his capacity as Sheriff of Chatham County,

and Meg Heap, in her capacity as District Attorney of Chatham County, filed the

underlying action for declaratory judgment against Media General,1 seeking a

declaration that the items requested were exempt from disclosure because they were

“part of an ongoing criminal investigation by the District Attorney’s Office.”2

In July 2015, the trial court entered judgment in favor of the CCSO and the

district attorney, finding that the records were exempt from release pursuant to OCGA

§ 50-18-72 (a) (4) because the prosecution was still pending. Media General appeals.

The material facts of this case are undisputed. Because the issue presented on

appeal is one of statutory construction, our review is de novo. See Hardaway Co. v.

Rives, 262 Ga. 631 (422 SE2d 854) (1992); Suarez v. Halbert, 246 Ga. App. 822, 824

(1) (543 SE2d 733) (2000).

Our analysis begins with the following principle:

1 The lawsuit named “WSAV, Inc.” as defendant. However, in the notice of appeal, appellant identifies itself as “Media General Operations, Inc. d/b/a WSAV- TV,” stating that it was “incorrectly sued in this action as ‘WSAV, Inc.’” 2 Members of Ajibade’s family intervened in the declaratory judgment action as defendants. They are not parties to this appeal.

4 Our General Assembly has expressly declared that “public access to public records should be encouraged to foster confidence in government and so that the public can evaluate the expenditure of public funds and the efficient and proper functioning of its institutions.” OCGA § 50-18-70 (a). To further this end, all public records are deemed subject to disclosure, “except those which by order of a court of this state or by law are specifically exempted from disclosure.” OCGA § 50-18-71 (a).

Schick v. Bd. of Regents of the Univ. Sys. of Ga., 334 Ga. App. 425, 429 (1) (779

SE2d 452) (2015); see Howard v. Sumter Free Press, 272 Ga. 521, 521-522 (1) (531

SE2d 698) (2000).

The exemption at issue is contained in OCGA § 50-18-72 (a) (4). That

subsection exempts from disclosure:

[r]ecords of law enforcement, prosecution, or regulatory agencies in any pending investigation or prosecution of criminal or unlawful activity, other than initial police arrest reports and initial incident reports; provided, however, that an investigation or prosecution shall no longer be deemed to be pending when all direct litigation involving such investigation and prosecution has become final or otherwise terminated; and provided, further, that this paragraph shall not apply to records in the possession of an agency that is the subject of the pending investigation or prosecution[.] (Emphasis supplied.)

5 In this case, it is undisputed that the video footage and IAD investigation

reports are public records and that the records are in the possession of the CCSO

and/or, more recently, the district attorney. The sole issue on appeal is whether the

records are exempt from public disclosure under the “pending prosecution”

exemption set out in OCGA § 50-18-72

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Related

Suarez v. Halbert
543 S.E.2d 733 (Court of Appeals of Georgia, 2000)
Hardaway Co. v. Rives
422 S.E.2d 854 (Supreme Court of Georgia, 1992)
Irvin v. MacOn Telegraph Publishing Co.
316 S.E.2d 449 (Supreme Court of Georgia, 1984)
Evans v. Georgia Bureau of Investigation
773 S.E.2d 725 (Supreme Court of Georgia, 2015)
Schick v. Board of Regents of the University System of Georgia
779 S.E.2d 452 (Court of Appeals of Georgia, 2015)
Howard v. Sumter Free Press, Inc.
531 S.E.2d 698 (Supreme Court of Georgia, 2000)

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Media General Operations, Inc. D/B/A Wsav-Tv v. Al St. Lawrence, Sheriff of Chatham County, Georgia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/media-general-operations-inc-dba-wsav-tv-v-al-st-lawrence-sheriff-of-gactapp-2016.