Maese v. Davis County
273 P.3d 949
Utah Ct. App.2012Background
- Maese appeals a trial court ruling granting Davis County’s Rule 12(b)(6) motion to dismiss his GRAMA claim.
- Maese’s GRAMA request sought a copy of the Davis County property transaction database in electronic form or a 20-year compiled transaction report.
- County responded that the records were accessible for free via Redi-Web and at the Recorder’s Office, not a full electronic copy.
- Maese contends the database is a distinct public record containing metadata not available online or in paper copies.
- The court addresses whether GRAMA requires providing a copy versus access and whether the database itself is a separate public record.
- GRAMA was satisfied by making records accessible; it does not require compiling or providing a format not currently maintained by the entity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether GRAMA requires a copy of the database rather than access | Maese argues the database itself must be provided as a public record | Davis County contends access and location of records suffice under GRAMA | No; access suffices and a copy is not required |
| Whether the database is a distinct public record under GRAMA | Maese asserts the database (with metadata) is a separate record | County treated the request as for records within the database | Unresolved in favor of ruling on access; court treats assertion as legal conclusion, not fact, and declines to decide |
| Whether Davis County complied with Maese’s actual GRAMA request | Maese maintains the requested electronic copy should be provided | County provided access and guidance to copy records | GRAMA satisfied by access and information on where to copy; no obligation to compile or provide electronic copy of entire database |
Key Cases Cited
- Valcarce v. Fitzgerald, 961 P.2d 305 (Utah 1998) (interpret GRAMA through plain language; access rights govern)
- Clover v. Snowbird Ski Resort, 808 P.2d 1037 (Utah 1991) (interpret terms in ordinary meanings under GRAMA)
- Maese v. Tooele Cnty., 2012 UT App 49 (Utah Court of Appeals, 2012) (compared to this case; access to records satisfies GRAMA)
- Miller v. State, 226 P.3d 743 (Utah 2010) (standard of review for Rule 12(b)(6) is correctness)
- Chapman ex rel. Chapman v. Primary Children’s Hosp., 784 P.2d 1181 (Utah 1989) (conclusory allegations insufficient to preclude dismissal)
- Williams v. Sprint/United Mgmt. Co., 230 F.R.D. 640 (D. Kan. 2005) (definition of metadata in discovery context)
- Aguilar v. Immigration & Customs Enforcement Div. of the U.S. Dept. of Homeland Sec., 255 F.R.D. 350 (S.D.N.Y. 2008) (metadata described; relevance to electronic records)