Department of Corrections v. St. Hilaire
128 A.3d 859
| Pa. Commw. Ct. | 2015Background
- ABC27 reporter Amanda St. Hilaire requested DOC records (Jan 2009–Dec 2014) documenting inmate injuries/deaths and employee injuries/deaths under the RTKL.
- DOC produced inmate death records but redacted causes of death, denied inmate injury and employee injury/death records citing insufficiency, exemptions (including medical records, law enforcement/public safety, investigations), and lack of employee-death records.
- OOR asked for and DOC submitted declarations describing recordkeeping: inmate medical files, separate monthly paper medical incident/injury reports at institutions, and an employee injury database. DOC asserted HIPAA concerns and burdensomeness.
- OOR granted the appeal in part: ordered DOC to produce de-identified medical incident/injury reports for inmate injuries and dismissed employee records issues as moot/waived.
- DOC petitioned for reconsideration and appealed to the Commonwealth Court, arguing: (1) the RTKL request was not sufficiently specific/was overbroad and (2) the incident/injury reports are exempt medical records under RTKL §708(b)(5).
Issues
| Issue | Plaintiff's Argument (St. Hilaire) | Defendant's Argument (DOC) | Held |
|---|---|---|---|
| Whether the RTKL request was sufficiently specific to require DOC to search for inmate injury records | Request identified subject (inmate injuries/deaths) and specific time frame (2009–2014); a clearly defined universe of documents | Request for “all records” is overbroad; would force DOC to review thousands and guess which reports document injuries | Request is sufficiently specific. Court distinguished Mollick and followed Legere: records sought are a clearly defined set (medical incident/injury reports) and burden does not render request overbroad |
| Whether monthly medical incident/injury reports are exempt medical records under RTKL §708(b)(5) | Requested non-identifiable injury information; records can be de-identified under §706; reports are not the same as individual medical treatment files | Reports may contain medical information and thus are exempt under §708(b)(5); redaction not enough because exempt records aren’t public records subject to §706 redaction | Reports are not categorically exempt. Because many reports are administrative and separate from individual medical files, responsive reports must be produced and may be redacted/de-identified under §706 |
Key Cases Cited
- Montgomery County v. Iverson, 50 A.3d 281 (Pa. Cmwlth. 2012) (RTKL specificity analyzed in request context)
- Department of Environmental Protection v. Legere, 50 A.3d 260 (Pa. Cmwlth. 2012) (requests for a clearly defined universe of documents not overbroad even if agency organization makes retrieval burdensome)
- Mollick v. Township of Worcester, 32 A.3d 859 (Pa. Cmwlth. 2011) (requests seeking “all” records on broad topics can be insufficiently specific)
- Heavens v. Pennsylvania Department of Environmental Protection, 65 A.3d 1069 (Pa. Cmwlth. 2013) (records exempt under §708 are not public records and need not be redacted under §706)