Maryland Department of State Police v. Maryland State Conference of NAACP Branches
430 Md. 179
| Md. | 2013Background
- NAACP requested records from Maryland State Police under MPIA, including item 6 about complaints of racial profiling and internal investigations.
- MSP produced some records but refused item 6, arguing they were personnel records exempt under § 10-616(i).
- NAACP sought declaratory judgment and inspection with redactions; federal consent decree required some reporting but not unredacted investigations to NAACP.
- Circuit Court held records are personnel records but ordered disclosure with redactions of trooper names, identifiers, and complainants.
- Court of Special Appeals vacated the موظtion on the personnel-records issue, accepted redaction-based disclosure framework, and this Court granted certiorari.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether redacted records can be disclosed under MPIA §§ 10-616(i) and 10-614. | NAACP argues redaction preserves disclosure while avoiding personnel-privacy concerns. | MSP contends records are personnel records and fully exempt; redaction does not resurrect disclosure. | Redacted records may be disclosed consistent with § 10-614(b)(3)(iii). |
| Are the records at issue within § 10-616(i) as personnel records even when redacted? | Redacted records lose individual-identifiable aspects and thus may fall outside 'personnel records.' | Redaction does not convert records from personnel records to non-personnel categories. | Redacted records are not necessarily exempt solely by their unredacted categorization; redaction can permit disclosure. |
| Do § 10-618(f) exemptions override or interact with § 10-616(i) for these records? | Redaction and § 10-618(f) may support disclosure of investigatory files proposed by the NAACP. | Exemptions in § 10-618(f) do not necessarily negate § 10-616(i) or require disclosure in full. | § 10-618(f) does not automatically overrule § 10-616(i); exemptions may coexist and apply. |
| Was the circuit court’s redaction order properly issued and appealable? | Redaction plan was appropriate to effect disclosure consistent with the Act. | Appealability and procedural posture of the redaction order are improper if not properly challenged. | Circuit Court’s redaction order properly supported disclosure with redactions. |
Key Cases Cited
- Kirwan v. The Diamondback, 352 Md. 74 (Md. 1998) (presumption of disclosure; broad construction of MPIA)
- Governor v. Washington Post Co., 360 Md. 520 (Md. 2000) (public policy favoring disclosure; interpretive framework)
- A.S. Abell Publishing Co. v. Mezzanote, 297 Md. 26 (Md. 1983) (liberal construction in favor of disclosure)
- Attorney General v. Gallagher, 359 Md. 341 (Md. 2000) (investigatory file exemptions do not override other exemptions)
- Montgomery County v. Shropshire, 420 Md. 362 (Md. 2011) (distinguishes personnel-records exemptions from investigative records)