Rutland Herald v. City of Rutland and AFSCME Council 93, Local 1201

2013 VT 98, 84 A.3d 821, 195 Vt. 85, 2013 Vt. 98, 2013 WL 5583262, 2013 Vt. LEXIS 93
CourtSupreme Court of Vermont
DecidedOctober 11, 2013
Docket2012-368
StatusPublished
Cited by4 cases

This text of 2013 VT 98 (Rutland Herald v. City of Rutland and AFSCME Council 93, Local 1201) is published on Counsel Stack Legal Research, covering Supreme Court of Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rutland Herald v. City of Rutland and AFSCME Council 93, Local 1201, 2013 VT 98, 84 A.3d 821, 195 Vt. 85, 2013 Vt. 98, 2013 WL 5583262, 2013 Vt. LEXIS 93 (Vt. 2013).

Opinion

2013 VT 98

Rutland Herald v. City of Rutland and AFSCME Council 93, Local No. 1201 (2012-368)

2013 VT 98

[Filed 11-Oct-2013]

NOTICE:  This opinion is subject to motions for reargument under V.R.A.P. 40 as well as formal revision before publication in the Vermont Reports.  Readers are requested to notify the Reporter of Decisions by email at: JUD.Reporter@state.vt.us or by mail at: Vermont Supreme Court, 109 State Street, Montpelier, Vermont 05609-0801, of any errors in order that corrections may be made before this opinion goes to press.

No. 2012-368

Rutland Herald

Supreme Court

On Appeal from

     v.

Superior Court, Rutland Unit,

Civil Division

City of Rutland and AFSCME Council 93, Local No. 1201

May Term, 2013

William D. Cohen, J.

Robert B. Hemley and Matthew B. Byrne of Gravel & Shea, PC, Burlington, for

  Plaintiff-Appellee.

Andrew Costello, Office of City Attorney, Rutland, for Defendant-Appellant.

PRESENT:   Reiber, C.J., Dooley, Skoglund and Burgess, JJ., and Zonay, Supr. J.,

                     Specially Assigned

¶ 1.             BURGESS, J.   The City of Rutland appeals from the trial court’s order, on remand, directing it to disclose certain records under the Vermont Public Records Act (PRA), 1 V.S.A. §§ 315-320.  The records concern several Rutland Police Department (RPD) employees who were investigated and disciplined for viewing and sending pornography on work computers while on duty.  The City argues that the trial court erred in evaluating the privacy interests at stake and concluding that the “personal records” exemption, 1 V.S.A. § 317(c)(7), did not apply.  We affirm.

¶ 2.             As recounted in our initial opinion, Rutland Herald v. City of Rutland, 2012 VT 26, 191 Vt. 387, 48 A.3d 568, the Rutland Herald learned via a 2009 search warrant that Rutland Police Department computers had been used to view and store pornography.  As part of its investigation, the Herald requested records from the City, including: the complete record of a 2004 internal investigation into RPD Employee #1’s alleged viewing of pornography at work, as well as letters from the police chief relating the employee’s status pending completion of the investigation and then imposing discipline following the investigation; similar materials from a 2010 investigation involving RPD Employee #2; materials related to a 2010 investigation of RPD Employee #3 for viewing pornography at work; and materials concerning the imposition of discipline in 2007 against two employees of the Department of Public Works (DPW) for violating the City’s internet usage policy. 

¶ 3.             The trial court reviewed these records in camera and, in a September 2010 decision, ordered their release with certain redactions.  The trial court rejected the City’s contention that the documents were exempt from disclosure under 1 V.S.A. § 317(c)(5), which applies to “records dealing with the detection and investigation of crime,” or under 1 V.S.A. § 317(c)(7), which excludes  “personal documents relating to an individual.”  On appeal, we affirmed the trial court’s decision as to the records concerning the DPW employees.  We reversed and remanded as to the remaining records, concluding that the trial court needed to assess, as a threshold matter, if the records dealt with “the detection and investigation of crime” under § 317(c)(5).  Because no final determination had yet been made as to the applicability of this exemption, we found it premature to address whether these documents would fall within 1 V.S.A. § 317(c)(7). 

¶ 4.             Following an evidentiary hearing on remand, the court concluded in September 2012 that certain documents were exempt from disclosure under 1 V.S.A. § 317(c)(5), while other documents, including the records at issue here, were not.  The court’s 2012 decision left in place its earlier September 2010 ruling that these records were not exempt under 1 V.S.A. § 317(c)(7). 

¶ 5.             Section 317(c)(7) exempts from public disclosure “personal documents relating to an individual, including information in any files maintained to hire, evaluate, promote or discipline any employee of a public agency, information in any files relating to personal finances, medical or psychological facts concerning any individual or corporation.”  We have construed the term “personal documents” to apply “only when the privacy of the individual is involved.”  Rutland Herald, 2012 VT 26, ¶ 39.  More specifically, “the exception applies only to those documents that reveal intimate details of a person’s life, including any information that might subject the person to embarrassment, harassment, disgrace, or loss of employment or friends.”  Kade v. Smith, 2006 VT 44, ¶ 8, 180 Vt. 554, 904 A.2d 1080 (mem.) (quotation omitted).

¶ 6.             In applying § 317(c)(7), the trial court must “balance the public interest in disclosure against the harm to the individual.”  Rutland Herald, 2012 VT 26, ¶ 11.  In doing so, it

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

Related

U.S. Right to Know v. University of Vermont
2021 VT 33 (Supreme Court of Vermont, 2021)
Peer News LLC v. City and County of Honolulu.
376 P.3d 1 (Hawaii Supreme Court, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
2013 VT 98, 84 A.3d 821, 195 Vt. 85, 2013 Vt. 98, 2013 WL 5583262, 2013 Vt. LEXIS 93, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rutland-herald-v-city-of-rutland-and-afscme-counci-vt-2013.