Champa v. Weston Public Schools
473 Mass. 86
| Mass. | 2015Background
- Weston Public Schools entered settlement agreements with parents resolving disputes over special-education services and out-of-district placements for school years 2007–2012.
- Michael Champa, a Weston resident, requested copies of all such agreements under the Massachusetts public records law.
- The school district withheld the agreements citing FERPA, Massachusetts student-records regulations, IDEA confidentiality, and confidentiality clauses in the agreements.
- The state Supervisor of Public Records upheld the withholding; Champa sued in Superior Court seeking disclosure.
- The Superior Court granted Champa judgment, ordering disclosure with redaction of student names and disability references; the school district appealed.
- The Supreme Judicial Court held the agreements are education/student records exempt from disclosure but must be produced after appropriate redaction; remanded to determine specific redactions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether settlement agreements are "public records" under G. L. c. 4, § 7, Twenty-sixth | Agreements are public records and not covered by student-record exemptions; should be disclosed (with limited redactions). | Agreements are education/student records exempt from public-records disclosure by statute and regulation (FERPA/IDEA/MA regs). | Agreements qualify as "education records" under FERPA and as student records under MA regs and thus fit within exemption (a); but redacted versions must be disclosed. |
| Whether FERPA/IDEA/MA student-records law bar disclosure of the agreements | Agreements do not solely concern academic progress and thus fall outside student-record protections. | FERPA and IDEA broadly define "education records" to include materials directly related to a student and maintained by the school; agreements fit this definition. | FERPA/IDEA/regulations cover the agreements; they contain personally identifiable student information and are protected absent redaction. |
| Whether privacy exemption (G. L. c. 4, § 7, Twenty-sixth (c)) prevents disclosure | Public interest outweighs privacy; redaction of names suffices. | Agreements link student identity to disability, program, and placements, causing stigma and invasion of privacy. | Exemption (c) applies to personally identifying portions; financial and non-identifying terms do not constitute unwarranted invasion and may be disclosed after redaction. |
| Whether contractual confidentiality clauses bar disclosure | Confidentiality clauses should not override public-records law. | Confidentiality clauses bind parties and should prevent disclosure. | Confidentiality provisions between private parties and a public agency cannot alone override statutory public-records obligations. |
Key Cases Cited
- Merriam v. Demoulas Super Mkts., Inc., 464 Mass. 721 (Mass. 2013) (standard of review for judgment on the pleadings)
- DaRosa v. New Bedford, 471 Mass. 446 (Mass. 2015) (public-records presumption of access)
- Globe Newspaper Co. v. Boston Retirement Bd., 388 Mass. 427 (Mass. 1983) (scope of public records and consideration of exempt portions)
- Collector of Lynn v. Attorney Gen., 377 Mass. 151 (Mass. 1979) (balancing privacy interests against public right to know)
- Department of the Air Force v. Rose, 425 U.S. 352 (U.S. 1976) (consideration of identifying information from vantage of those familiar with the individual)
- Ackerly v. Ley, 420 F.2d 1336 (D.C. Cir. 1969) (confidentiality undertakings cannot automatically override disclosure statutes)