T. Mutchler and Obermayer Rebmann Maxwell & Hippel v. PA OA (OOR)

CourtCommonwealth Court of Pennsylvania
DecidedMarch 18, 2025
Docket628 C.D. 2023
StatusPublished

This text of T. Mutchler and Obermayer Rebmann Maxwell & Hippel v. PA OA (OOR) (T. Mutchler and Obermayer Rebmann Maxwell & Hippel v. PA OA (OOR)) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
T. Mutchler and Obermayer Rebmann Maxwell & Hippel v. PA OA (OOR), (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Terry Mutchler and Obermayer : Rebmann Maxwell & Hippel, : Petitioners : v. : : Pennsylvania Office of Administration : (Office of Open Records), : No. 628 C.D. 2023 Respondent : Argued: December 11, 2024

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE LORI A. DUMAS, Judge HONORABLE STACY WALLACE, Judge HONORABLE MATTHEW S. WOLF, Judge

OPINION BY JUDGE FIZZANO CANNON FILED: March 18, 2025

Terry Mutchler and Obermayer Rebmann Maxwell & Hippel (Requesters) petition for review of a final determination of the Office of Open Records (OOR) under the Right-to-Know Law (RTKL).1 Upon review, we affirm.

I. Background The Pennsylvania Justice Network (JNET) exists under the auspices of the Pennsylvania Office of Administration (OA), Public Safety Delivery Center. JNET is a web-based portal through which authorized users in the Commonwealth can access public safety and criminal justice information maintained by separate

1 Act of February 14, 2008, P.L. 6, 65 P.S. §§ 67.101-67.3104. third-party data providers. See https://www.pa.gov/agencies/jnet.html (last visited March 17, 2025). The data available through JNET comes from various contributing municipal, county, state, and federal agencies and is used by law enforcement and public safety officials at the federal, state, and local levels in Pennsylvania. Users include, inter alia, employees of state and municipal police. Id. Requesters believe that a police officer from the Camp Hill Police Department (CHPD) conducted an unauthorized search in JNET. Requesters describe alleged text messages between the police officer and his girlfriend in which he allegedly agreed to conduct an unauthorized search “so she could monitor the activities of her boss and co-worker.” Requesters’ Br. at 14. Testing that belief, Requesters submitted an information request to Camp Hill Borough (Borough) in 2022, seeking “all documentation and/or computer records of any non-investigatory (i.e., not associated with any criminal investigation) [JNET] searches performed by [the specified CHPD police officer] between January 1, 2020 and the present.” Mutchler and Obermayer Rebmann Maxwell & Hippel, LLP v. Camp Hill Borough (OOR Dkt. No. AP 2022-2494, decided Dec. 19, 2022) (Mutchler I), slip op. at 1. The Borough denied the request, and Requesters appealed to OOR, which denied the appeal in a final determination in December 2022. In denying Requesters’ appeal, OOR determined that Requesters failed to identify a discrete group of documents that were responsive, explaining: [The request] does not merely seek logs of searches or the searches themselves; instead, it asks the Borough to survey the searches/logs and only provide information that is “non-investigatory.” This leads to a situation where a [CHPD] employee would be left to guess what information is “non-investigatory,” and that defect makes the request insufficiently specific.

2 Mutchler I, slip op. at 8 (footnote omitted). “In other words, judgments would need to be made based upon context and information that may not be available to the individual conducting the search.” Id., slip op. at 8 n.6. Requesters did not seek judicial review of OOR’s final determination. Instead, they initiated the January 2023 request to OA at issue here. Of the 13 items of information Requesters sought from OA, 6 remain unresolved: 6. A copy of records that reflect the suspension of access issued by JNET or its Steering Committee to [CHPD] and/or any [CHPD] police officers or employees between January 1, 2020 and the date of this request. 7. A copy of records that reflect administrative sanctions, other than suspension of access, by JNET or its Steering Committee to [CHPD] and/or any [CHPD] police officers or employees between January 1, 2020 and the date of this request. 8. A list of the names of JNET users employed by [CHPD] who have been investigated for and/or disciplined for violating any policies pertaining to JNET usage between January 1, 2020 and the date of this request. 9. A copy of records of all audits of JNET usage by [CHPD] or any of its officers or employees, performed by JNET or the JNET steering committee between January 1, 2020 and the date of this request. 10. A copy of records associated with the termination, suspension or other disciplinary action by JNET or the JNET steering committee against [CHPD] or any of its officers and employees between January 1, 2020 and the date of this request. . . .

11. . . . A copy of reports of incidents, received by JNET from [CHPD] or any of its personnel, involving confirmed or suspected unauthorized or accidental modification, destruction, disclosure, loss, damage, misuse, or access to JNET information technology resources such as systems, files, services, and data

3 bases, between January 1, 2020 and the date of this request. May 16, 2023 OOR Final Determination at 1-2. OA invoked a 30-day extension in which to consider the request pursuant to Section 902(b)(2) of the RTKL, 65 P.S. § 67.902(b)(2).2 When OA failed to meet that deadline, the request was deemed denied on March 8, 2023. Id. Nonetheless, OA issued a partial denial of the request on March 9, 2023. Regarding Items 6-11, OA asserted that no records responsive to those items exist within OA’s possession, custody, or control. Requesters challenged OA’s partial denial before OOR and requested a hearing. Both parties submitted position statements. OA reiterated its grounds for its denial and submitted two attestations, one from its open records officer Wha Lee Strohecker (Strohecker Attestation) and the second from its information technology employee Joseph Centurione (Centurione Attestation). Requesters renewed their request for a hearing, and OA objected to the hearing request. In the OOR appeal, OA submitted additional information, including a document titled “JNET Policies and Procedures Misuse Investigation Procedures

2 Section 902(b)(2) of the RTKL provides:

(2) The notice [that a record request has been received] shall include a statement notifying the requester that the request for access is being reviewed, the reason for the review, a reasonable date that a response is expected to be provided and an estimate of applicable fees owed when the record becomes available. If the date that a response is expected to be provided is in excess of 30 days, following the five business days allowed for in [S]ection 901, [65 P.S. § 67.901,] the request for access shall be deemed denied unless the requester has agreed in writing to an extension to the date specified in the notice.

65 P.S. § 67.902(b)(2).

4 dated March 10, 2019, version 2.7” and copies of four separate agreements that OA uses with local agencies and their individual users who access JNET. May 16, 2023 OOR Final Determination at 4 n.3 & 5 n.4. In its final determination, OOR denied Requesters’ request for a hearing, dismissed the appeal as moot in part because OA had provided additional records, and denied the remainder of the appeal, determining that OA met its burden of proving there were no records responsive to Items 6-11 in its possession, custody, or control and that OA was not required to seek such records from CHPD. Specifically, OOR concluded it was “unable to direct access to a third party’s records simply because there is an agreement between the agency and the third party.” Id. at 10 n.7. OOR determined there was no indication of a “contractual relationship between [OA] and any local government users of JNET to perform any of [OA’s] governmental functions, which would require [OA] to contact [CHPD] as part of a good faith search of records responsive to the [r]equest.” Id. at 9. Requesters’ petition for review in this Court followed.

II.

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T. Mutchler and Obermayer Rebmann Maxwell & Hippel v. PA OA (OOR), Counsel Stack Legal Research, https://law.counselstack.com/opinion/t-mutchler-and-obermayer-rebmann-maxwell-hippel-v-pa-oa-oor-pacommwct-2025.