U.S. Right to Know v. University of Vermont

2021 VT 33
CourtSupreme Court of Vermont
DecidedMay 14, 2021
Docket2020-110
StatusPublished
Cited by1 cases

This text of 2021 VT 33 (U.S. Right to Know v. University of Vermont) 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
U.S. Right to Know v. University of Vermont, 2021 VT 33 (Vt. 2021).

Opinion

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@vermont.gov 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.

2021 VT 33

No. 2020-110

U.S. Right to Know Supreme Court

On Appeal from v. Superior Court, Chittenden Unit, Civil Division

University of Vermont September Term, 2020

Helen M. Toor, J.

Stephen F. Coteus and Ronald A. Shems of Tarrant, Gillies, Richardson & Shems, Montpelier, for Plaintiff-Appellant.

Sharon Reich Paulsen, Vice President and General Counsel, and Meghan E. Siket, Associate General Counsel, Office of General Counsel University of Vermont, Burlington, for Defendant-Appellee.

PRESENT: Reiber, C.J., Robinson, Eaton, Carroll and Cohen, JJ.

¶ 1. COHEN, J. In this Public Records Act (PRA) case we are asked to determine

whether emails on a university’s server sent between a professor and third-party entities, and

concerning the work of those entities, qualify as “public records” subject to public inspection. U.S.

Right to Know (USRTK) appeals from the superior court’s grant of summary judgment in favor

of the University of Vermont (UVM) after the court held that the emails USRTK requested from

UVM are not public records. We agree that the emails at issue are not public records and

accordingly affirm. ¶ 2. The following facts are uncontested. Professor Naomi Fukagawa is a retired

professor of UVM’s Larner College of Medicine who has served as an editor of two peer-reviewed

academic journals—Nutrition Reviews and the American Journal of Clinical Nutrition. Dr.

Fukagawa has also served on two advisory committees associated with the U.S. government and

the University of Illinois at Urbana-Champaign. Although the journals and committees are not

affiliated with UVM, before and after her retirement, Dr. Fukagawa used her UVM email account

to correspond with individuals affiliated with the journals and committees.

¶ 3. In March 2018, USRTK, a nonprofit public-health research organization, made a

PRA request to UVM, seeking emails on UVM’s server between Professor Fukagawa and named

persons associated with the journals and committees during a specified timeframe. UVM’s search

returned 10,140 potentially responsive emails. The parties agree that the emails are “almost

exclusively related” to Dr. Fukagawa’s editorial roles on the journals and her work on the

committees. USRTK is clear that it is seeking Professor Fukagawa’s emails related to her work

on the journals and committees, not other emails caught in the requested search parameters.

¶ 4. In March 2019, UVM responded to the records request, asserting that the emails

are not “public records” subject to disclosure under the PRA because the journals and committees

are not affiliated with UVM and Professor Fukagawa corresponded with these entities in her

personal capacity. Following an unsuccessful appeal to UVM’s president and an ineffective

amended request expanding the timeframe of requested emails, USRTK filed suit in the superior

court to compel disclosure.

¶ 5. The superior court granted UVM’s motion for summary judgment, ruling that the

emails are not public records because they were not “produced or acquired in the course of public

agency business.” See 1 V.S.A. § 317(b) (defining “public record”). The court observed that the

purpose of the PRA is to ensure that the public can review and criticize government—not private—

2 action. Finding that the emails played no role in the University’s business, the court concluded

that there was no government role at issue in need of public inspection.

¶ 6. On appeal, USRTK first argues that UVM bears the burden of proof to support its

action of withholding the emails, a burden USRTK claims has not been met. USRTK then

advances several premises in support of its argument that the emails are public records. First, it

observes that the emails were sent using the University’s email system. Second, it argues that the

professor was acting within the scope of her employment, which it equates with “in the course of

public agency business,” because (a) UVM’s email policy requires employees to use their UVM

email account exclusively for UVM business, except for “occasional and incidental non-University

matters,” and (b) UVM benefits from, encourages, expects, promotes—and spends public funds

promoting—the professor’s work on such journals and committees.

¶ 7. This Court reviews a decision granting summary judgment without deference and

applies the same standard as the superior court. Wesco, Inc. v. Sorrell, 2004 VT 102, ¶ 9, 177 Vt.

287, 865 A.2d 350. A grant of summary judgment is appropriate “if the movant shows that there

is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of

law.” V.R.C.P. 56(a).

¶ 8. The PRA seeks to provide the people a means of examining public records so they

may review and criticize the actions of their government. See 1 V.S.A. § 315(a). To that end, the

Act provides that “[a]ny person may inspect or copy any public record of a public agency.” Id.

§ 316(a). “Public record” is defined as “any written or recorded information, regardless of physical

form or characteristics, which is produced or acquired in the course of public agency business.”

Id. § 317(b). Certain public records are nevertheless exempted from public inspection for a host

of reasons, such as confidentiality and privilege. See id. § 317(c). A person aggrieved by the

denial of a request for public records may pursue relief in court, where the agency bears the burden

of proof to sustain its action. Id. § 319(a).

3 ¶ 9. As an initial matter, there is nothing for us to add here regarding the burden of

proof. See Trombley v. Bellows Falls Union High Sch. Dist. No. 27, 160 Vt. 101, 107, 624 A.2d

857, 861 (1993) (“In a dispute over access in the trial court, the burden is on the agency to sustain

its action.” (citing 1 V.S.A. § 319(a))). The facts of this case are not disputed. The parties filed a

joint statement of undisputed facts where they agree that the emails are “almost exclusively

related” to Dr. Fukagawa’s editorial roles on the journals and her work on the committees. The

statement is also clear that USRTK is seeking Professor Fukagawa’s emails related to her work on

the journals and committees, not, for example, emails to these entities related to her work at UVM,

which would present us with an altogether different case. Moreover, the parties do not dispute that

UVM qualifies as a public agency under the PRA. See Animal Legal Def. Fund, Inc. v.

Institutional Animal Care & Use Comm. of Univ. of Vt., 159 Vt. 133, 140, 616 A.2d 224, 227

(1992) (holding that UVM is subject to PRA). Accordingly, the only issue before us is whether,

as a matter of law, the emails related to Dr. Fukagawa’s work on the journals and committees are

public records under the PRA.

¶ 10. We hold that the emails are not public records because they were not produced or

acquired in the course of public agency business. We reach this conclusion based on the language

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