Vt Journalism Trust v. Doc

CourtVermont Superior Court
DecidedFebruary 4, 2026
Docket171-3-19 wncv
StatusUnknown

This text of Vt Journalism Trust v. Doc (Vt Journalism Trust v. Doc) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vt Journalism Trust v. Doc, (Vt. Ct. App. 2026).

Opinion

SUPERIOR COURT

IVIL DIVISION ocket No. 171-3-19 Wnev

SUPERIOR COURT Dw ok PSs Washington Unit Ty SEP -U ;

Vermont Journalism Trust Plaintiff

Vv.

Vermont Department of Corrections,

Mike Touchette, Commissioner of the

Vermont Department of Corrections Defendants

Opinion and Order on Cross-Motions for Summary Judgment

This is a public records case in which Plaintiff the Vermont Journalism Trust (Trust) has sought the production of certain public records from Defendant the Vermont Department of Corrections (DOC). See 1 V.S.A. §§ 315-320 (Access to Public Records Act (PRA)). The records sought relate toa specific DOC employee, Edward Adams, who the Trust believes was subject to internal claims of sexual harassment and may have been transferred as a result from his Superintendent position to a lower-level job within the DOC. Following extensive prior proceedings, the controversy has boiled down to the propriety of redactions the State has made to 8 pages of otherwise produced documents.! The parties have filed cross-motions for

summary judgment addressing the legal bases for those redactions.

1 The State produced many previously withheld documents after Mr. Adams assented to their release. In briefing, the State asserts that release of those documents would have been improper under the PRA otherwise. The Court has not so ruled, however. As a general matter, the State argues that the redactions properly conceal information that is confidential, 1 V.S.A. § 317(c)(1), or privileged, id. § 317(c)(4), by law pursuant to 3 V.S.A. § 316 and 12 V.S.A. § 1691a. Otherwise, the State argues that the redactions properly conceal information that is subject to the PRA exemptions for personal documents, 1 V.S.A. § 317(c)(7), and information that could be used to identify one who has complained about governmental waste, fraud, or abuse of authority, id. § 317(©)(42). The Trust argues that there is no lawful privilege or confidentiality at issue in this case, that a compelling public interest in Mr. Adams’ conduct or treatment within the DOC competes against concealment under the personal documents exemption, and that the Court should apply the waste, fraud, or abuse exemption narrowly.

The parties have stipulated to the Court’s in camera review of the remaining disputed documents. The Court has reviewed the unredacted documents and the State’s proposed redactions and now makes the following determinations.

I. 1 V.S.A. § 317(c)(1), (c)(4)

The PRA includes exemptions for information that is designated confidential by law or subject to statutory or common law privilege. 1 V.S.A. § 317(c)(1), (©)(4). The State argues that 3 V.S.A. § 316 makes the remaining records confidential by law, and 12 V.S.A. § 1691a extends a statutory privilege to them. The Court is not persuaded by either argument.

Under 3 V.S.A. § 316, “[t]he records of the Department, except such records as

the rules may properly require to be held confidential for reasons of public policy, shall be public records and shall be open to public inspection, subject to reasonable regulations as to the time and manner of inspection as may be prescribed by the Commissioner.” 3 V.S.A. § 316 (emphasis added). The State argues that Department of Human Resources (DHR) Policies 5.4 and 7 are “rules” that operate to exempt certain human resources records from the PRA.

Assuming, without deciding, that § 316 reflects some delegation of authority to the Commissioner of Human Resources to exercise formal rulemaking authority to exempt certain DHR records from the PRA, .the State has come forward with no such “rule” purporting to do any such thing. “Rule” is a term of art generally defined to mean an “agency statement of general applicability that implements, interprets, or prescribes law or policy and that has been adopted in the manner provided by” 3 V.S.A. §§ 836—844 of the Vermont Administrative Procedures Act (VAPA). The State points to DHR policies 5.4 and 7, but there is no dispute that neither is a VAPA rule.

To the extent that the State asserts that the Court should defer to its interpretation of 3 V.S.A. § 316, the Court declines. The Court generally will defer to an agency’s interpretation of its own statutory authority if that interpretation is at least one among the available reasonable such interpretations. See Athens Sch. Dist. v. Vermont State Bd. of Educ., 2020 VT 52, § 18. But that is not.the case here. The State’s interpretation, effectively that “rule” means whatever DHR says, ignores the significance of the statute’s use of a well-known term of art and would

completely undermine the open scrutiny under VAPA to which any such rulemaking would be subject and through which possible impacts on the PRA could be fully vetted. The State’s broad interpretation of 3 V.S.A. § 316 is not reasonable.

Moreover, DHR policy 5.4 expressly says that the employee information to which it applies may be accessed pursuant to the PRA. See DHR Policy 5.4 at 4. DHR policy 7 also does not clearly purport to create any exemption from the PRA. While it speaks of confidentiality of investigative reports, it also says that they “may be released only after consultation with DHR.” DHR Policy 7 at 4. These are internal operating policies of the Department. There is no indication that they were intended to operate as generally applicable exemptions to the PRA.

The State separately argues that 12 V.S.A. § 1691a establishes a statutory privilege applicable to personnel records, exempting them from the PRA. Section 1691a establishes a procedure for the production of personnel records in discovery in a civil action ensuring that the affected employee has notice and an opportunity to object prior to production. Section 1691a does not establish a general privilege of any sort and it is wholly irrelevant to the PRA. The PRA addresses the production of public records on request pursuant to statute. Section 1691a addresses discovery in a civil action. Production pursuant to the PRA and discovery in a civil action are entirely separate subject matters. See Wesco, Inc. v. Sorrell, 2004 VT 102, § 22, 177 Vt. 287, 296. Section 1691a has no bearing on this case.

Il. 1 V.S.A. § 317(c)(7), (c)(42)

The other exemptions relied upon by the State plainly apply to the disputed

documents. The personal documents exemption (Exemption 7) protects information revealing the “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.” Trombley v. Bellows Falls Union High Sch. Dist. No. 27, 160 Vt. 101, 110 (1993) (citation omitted). Against that privacy interest, the Court weighs the “public interest in disclosure.” Kade v. Smith, 2006 VT 44, J 8, 180 Vt. 554, 55 (citation omitted).

Exemption 42 protects “information that could be used to identify a complainant who alleges that a public agency, a public employee or official .. . has engaged in a violation of law, or in waste, fraud, or abuse of authority, or in an act creating a threat to health or safety, unless the complainant consents to disclosure of his or her identity.” 1 V.S.A. § 317(c)(42). While there are no reported cases further explicating Exemption 42, in the context of this case, it is reasonably clear on its face. As with all exemptions, “exceptions to disclosure are construed strictly against the custodian of the records, and we resolve any doubt in favor of disclosure.” Sawyer v. Spaulding, 2008 VT 68, J 8, 184 Vt. 545, 547.

Ill. The Documents and Redactions in Controversy

The remaining pages in dispute are “bates” numbered DOC 17, 18, 19, 20, 21, 60, 61, and 64.

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Related

Trombley v. Bellows Falls Union High School District No. 27
624 A.2d 857 (Supreme Court of Vermont, 1993)
Sawyer v. Spaulding
2008 VT 63 (Supreme Court of Vermont, 2008)
In Re South Burlington/Shelburne Highway
2008 VT 68 (Supreme Court of Vermont, 2008)
Athens School District v. Vermont State Board of Education
2020 VT 52 (Supreme Court of Vermont, 2020)
Wesco, Inc. v. Sorrell
2004 VT 102 (Supreme Court of Vermont, 2004)
Kade v. Smith
2006 VT 44 (Supreme Court of Vermont, 2006)

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Vt Journalism Trust v. Doc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vt-journalism-trust-v-doc-vtsuperct-2026.