Barros v. Martin
92 A.3d 1243
Pa. Commw. Ct.2014Background
- Appellant Cesar Barros, an inmate convicted of homicide, requested various investigative records (complaint file, Quinones’ alleged confession and polygraph, forensic lab reports, 911/CAD logs, wanted notice, witness statements) from the Lehigh County District Attorney under the RTKL and CHRIA.
- The District Attorney (appeals officer designated for criminal-investigative records) denied the request, citing the RTKL exemption for records relating to criminal investigations (Section 708(b)(16)(ii)); the DA also noted prior denials by the City of Allentown and a related pending appeal.
- Barros appealed the DA’s final determination to the Court of Common Pleas; the trial court concluded his appeal was untimely (rejecting his invocation of the prisoner-mailbox rule) but also reached the merits and affirmed denial under RTKL/CHRIA; Barros pursued further appellate review.
- The Commonwealth Court found Barros had timely mailed his petition under the prisoner-mailbox rule, so the timeliness dismissal was erroneous, but nonetheless affirmed the trial court’s denial on the merits.
- The court held the requested records were exempt as criminal investigative materials under the RTKL and also protected as investigative information under CHRIA; discretionary release under RTKL §506(c) was precluded because other state law (CHRIA) barred disclosure.
- The court rejected Barros’ alternate theories (common-law access to judicial documents, mandamus/declaratory relief to remedy alleged discovery violations, habeas ad testificandum request) as either unsupported by the record or inappropriate vehicles for attacking his conviction (PCRA is exclusive).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness under prisoner-mailbox rule | Barros: petition delivered to prison authorities Dec 17/18, so filed within 30 days | DA: petition docketed Jan 18; untimely | Court: prisoner-mailbox rule applies; petition timely mailed Dec 17/18; trial court erred dismissing as untimely |
| RTKL access to criminal-investigative records | Barros: public interest/§506(c)(3) and common-law judicial access (confession/polygraph) justify disclosure | DA: records relate to criminal investigation and are exempt under RTKL §708(b)(16)(ii); CHRIA also bars disclosure | Court: records exempt under RTKL §708(b)(16)(ii) and CHRIA; §506(c) discretionary release unavailable where other law prohibits disclosure; denial affirmed |
| Existence / public judicial record status of Quinones’ confession/polygraph | Barros: those items were placed into judicial record at Quinones’ sentencing and thus accessible | DA: no evidence those materials were part of the judicial record; DA denies existence | Court: no record evidence that confession/polygraph were part of judicial record; cannot compel production of non-existent or non-judicial materials |
| Appropriateness of mandamus/declaratory relief to remedy alleged discovery violations | Barros: seeks declaratory/mandamus to obtain materials he claims should have been disclosed in his criminal case | DA: civil remedies improper; PCRA is exclusive remedy for collateral attack on conviction | Court: mandamus/declaratory relief improper here; PCRA is exclusive vehicle for relief related to conviction |
Key Cases Cited
- Coley v. Philadelphia Dist. Attorney’s Office, 77 A.3d 694 (Pa. Cmwlth.) (criminal investigative records exempt under RTKL §708(b)(16))
- Mitchell v. Office of Open Records, 997 A.2d 1262 (Pa. Cmwlth.) (RTKL exemption for investigative materials applies even after investigation concludes)
- Department of Health v. Office of Open Records, 4 A.3d 803 (Pa. Cmwlth.) (§506(c) grants discretion to release but does not mandate disclosure)
- Department of Conservation & Natural Resources v. Office of Open Records, 1 A.3d 929 (Pa. Cmwlth.) (discretionary disclosure under §506(c) is prohibited where other law forbids release)
- Guarrasi v. Scott, 25 A.3d 394 (Pa. Cmwlth.) (RTKL provides exclusive remedy for RTKL claims; common-law access to judicial records considered in RTKL context)
- Commonwealth v. Martinez, 917 A.2d 856 (Pa. Super.) (supervisory power and limits on common-law right to inspect judicial records)