Theodore Edward Rokita v. Barbara Tully

CourtIndiana Court of Appeals
DecidedApril 29, 2024
Docket23A-PL-00705
StatusPublished

This text of Theodore Edward Rokita v. Barbara Tully (Theodore Edward Rokita v. Barbara Tully) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Theodore Edward Rokita v. Barbara Tully, (Ind. Ct. App. 2024).

Opinion

IN THE

Court of Appeals of Indiana Theodore Rokita, FILED Appellant/Cross-Appellee-Defendant Apr 29 2024, 8:44 am

CLERK Indiana Supreme Court v. Court of Appeals and Tax Court

Barbara Tully, Appellee/Cross-Appellant-Plaintiff

April 29, 2024 Court of Appeals Case No. 23A-PL-705 Appeal from the Marion Superior Court The Honorable Kurt Eisgruber, Judge Trial Court Cause No. 49D06-2107-PL-25333

Opinion by Judge Kenworthy Chief Judge Altice and Judge Foley concur.

Court of Appeals of Indiana | Opinion 23A-PL-705 | April 29, 2024 Page 1 of 23 Kenworthy, Judge.

Case Summary [1] Barabara Tully requested information from the Office of the Indiana Attorney

General (“OAG”) regarding an informal advisory opinion issued to Attorney

General Theodore Rokita by the Indiana Office of Inspector General (“OIG”).

The OAG declined to give Tully access, claiming the opinion was confidential

and not subject to disclosure under Indiana’s Access to Public Records Act

(“APRA”). After the Indiana Public Access Counselor (“PAC”) also

concluded the opinion was excepted from disclosure, Tully sued Attorney

General Rokita, alleging a violation of APRA. The trial court granted Tully

summary judgment and Attorney General Rokita appealed.

[2] But while this appeal was pending, the Indiana General Assembly added a

wrinkle: it amended the statute relating to the Inspector General’s duties and

made that amendment retroactive. The amended statute explicitly provides the

Inspector General’s informal advisory opinions are confidential and excepted

from disclosure under APRA. Based on this turn of events, we reverse and

remand with instructions.

Facts and Procedural History A. Indiana Office of Inspector General

[3] Created in 2005, the OIG is tasked with “addressing fraud, waste, abuse, and

wrongdoing” in state agencies. Ind. Code § 4-2-7-2(b). To help achieve this

goal, the General Assembly directed the OIG to implement a code of ethics for Court of Appeals of Indiana | Opinion 23A-PL-705 | April 29, 2024 Page 2 of 23 state government through rulemaking. See I.C. §§ 4-2-7-3(6), 4-2-7-5(a). The

OIG did so by establishing the Indiana Code of Ethics. See 42 Ind. Admin.

Code 1-1-1 et seq. Relevant to this appeal are Rules 5 and 8 of that Code. 42

I.A.C. 1-5-1 et. seq (“Rule 5”); 42 I.A.C. 1-8-1 (“Rule 8”). Rule 5 sets forth the

Ethics Rules, one of which specifically concerns outside-employment

restrictions for state employees. See 42 I.A.C. 1-5-5. Rule 8 grants the

Inspector General, or its designee, the “authority to render informal advisory

opinions.” 42 I.A.C. 1-8-1(a). Such opinions are “expressions of opinion that

are communicated for the purpose of deliberation and decision making” that

“shall be considered confidential under IC 5-14-3-4(b)(6).” 42 I.A.C. 1-8-1(b).

Through Rule 8’s process, the OIG issues around 215 to 375 informal advisory

opinions per year to Indiana state employees seeking prospective ethical advice.

See Appellant’s App. Vol. 2 at 161.

B. Indiana Access to Public Records Act

[4] In 1983, the Indiana General Assembly passed APRA 1 with the express

purpose that “all persons are entitled to full and complete information regarding

the affairs of government and the official acts of those who represent them as

public officials and employees.” I.C. § 5-14-3-1. To serve this purpose, APRA

provides: “Any person may inspect and copy the public records of any agency

during the regular business hours of the agency.” I.C. § 5-14-3-3(a). And

1 See I.C. §§ 5-14-3-1 through 5-14-3-10.

Court of Appeals of Indiana | Opinion 23A-PL-705 | April 29, 2024 Page 3 of 23 because APRA is intended to ensure Hoosiers have broad access to most

government records, APRA is to be “liberally construed,” and places the

burden for nondisclosure of a public record “on the public agency that would

deny access to the record and not on the person seeking to inspect and copy the

record.” I.C. § 5-14-3-1.

[5] However, certain categories of public records are excepted from APRA’s

disclosure requirement. See I.C. § 5-14-3-4. Some records are excepted unless

disclosure is specifically required by statute or court order, I.C. § 5-14-3-4(a),

while others are excepted at the discretion of a public agency, I.C. § 5-14-3-4(b).

A member of the public or a public agency can make an informal inquiry or

request a formal advisory opinion from the PAC regarding whether a document

is subject to disclosure under APRA. See I.C. § 5-14-4-10(5), (6).

[6] But an opinion from the PAC does not have to be the end of the road. Rather,

a person denied access to a public record may file an action in court “to compel

the public agency to permit the person to inspect and copy the public record.”

I.C. § 5-14-3-9(e). If the plaintiff seeking disclosure prevails in the court action,

the court “shall” award reasonable attorney fees, court costs, and expenses if

the plaintiff first sought and received an informal inquiry response or formal

advisory opinion from the PAC. 2 I.C. § 5-14-3-9(i).

2 Due to this incentive, most cases involving APRA begin as complaints with the PAC. See, e.g., ESPN, Inc. v. Univ. of Notre Dame Police Dep’t, 62 N.E.3d 1192 (Ind. 2016); Citizens Action Coal. of Ind. v. Koch, 51 N.E.3d 236

Court of Appeals of Indiana | Opinion 23A-PL-705 | April 29, 2024 Page 4 of 23 C. Tully’s APRA Request and Subsequent History

[7] Soon after Attorney General Rokita assumed office in January 2021, he sought

and received an informal advisory opinion from the OIG relating to the ethical

implications of his continued outside employment with Apex Benefits. A few

weeks later, the Indianapolis Business Journal ran an article about the OIG

opinion. In the article, a spokesperson for the OAG confirmed Attorney

General Rokita had sought and received an opinion from the OIG and assured

the opinion clarified Attorney General Rokita’s “interests and outside

employment are all squarely within the boundaries of the law and do not

conflict with his official duties.” Appellant’s App. Vol. 2 at 51.

[8] Tully then submitted a written public records request to Attorney General

Rokita seeking access to the OIG opinion. When the OAG refused to provide

her with a copy, claiming the OIG opinion was confidential under Rule 8, Tully

turned to the PAC. And after the PAC agreed with the OAG that the opinion

was confidential under Rule 8 and not subject to disclosure under APRA, Tully

sued Attorney General Rokita.

[9] In the trial court, both parties moved for summary judgment. According to

Attorney General Rokita, the deliberative materials exception to disclosure

specifically referenced in Rule 8 excepted the OIG opinion he received from

disclosure. See I.C. § 5-14-3-4(b)(6). The trial court disagreed and granted Tully

(Ind. 2016); see also Courtney Abshire, Public Business is the Public’s Business: Koch’s Implications for Indiana’s Access to Public Records Act, 52 Ind. L. Rev. 455, 458 (2019).

Court of Appeals of Indiana | Opinion 23A-PL-705 | April 29, 2024 Page 5 of 23 summary judgment, finding Rule 8 “is not harmonious” with Rule 5.

Appellant’s App. Vol. 2 at 14. In the trial court’s view, accepting Attorney

General Rokita’s reasoning “would allow a state employee to determine

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