Laramie County School District No. One v. Cheyenne Newspapers, Inc.
250 P.3d 522
Wyo.2011Background
- WPRA request for records listing employee names with salaries; district refused, citing WEC § 21-3-110(a)(ii)(A) restricting disclosure by category.
- Plaintiffs sued within three months; district argued disclosure would violate WEC and potentially harm public interest for specific employees.
- WPRA generally requires public records be open; employment terms and conditions are public records under § 16-4-203(d)(iii).
- Court acknowledged the public’s right to know how public funds are spent and that salary information falls within terms and conditions of public employment.
- Court rejected district’s statutory interpretation that WEC precludes sharing individual salaries; held WPRA supersedes the categorization in WEC for general disclosure.
- Final order granted summary judgment for plaintiffs, requiring disclosure of individual salaries with names, subject to privacy redactions where appropriate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether WPRA, read with WEC, requires disclosure of names with salaries | Newspaper: must disclose as terms of employment under WPRA | District: WEC § 21-3-110(a)(ii)(A) limits disclosure to category-based salary data | Yes; WPRA requires disclosure of names and salaries. |
| Whether WEC creates an exception exempting individual salaries from disclosure | Disclosures allowed under WPRA not overridden by WEC | WEC controls the format and disclosure scope, possibly secreting identities | No; WEC does not expressly exempt identity-linked salary data when requested under WPRA. |
Key Cases Cited
- Freudenthal v. Cheyenne Newspapers, Inc., 2010 WY 80 (Wyoming Supreme Court, 2010) (reinforces openness of records and limited exceptions)
- Laramie River Conservation Council v. Dinger, 567 P.2d 731 (Wyoming Supreme Court, 1977) (fishbowl governmental records presumption and public access)
- Allsop v. Cheyenne Newspapers, Inc., 39 P.3d 1092 (Wyoming Supreme Court, 2002) (limits discretionary exemptions from disclosure)
- Houghton v. Franscell, 870 P.2d 1050 (Wyoming Supreme Court, 1994) (public access to terms and conditions of public employment; broad disclosure)
- Sheridan Newspapers, Inc. v. City of Sheridan, 660 P.2d 785 (Wyoming Supreme Court, 1983) (constitutional protections and limits on discretionary exemptions)