173 A.3d 1162
Pa.2017Background
- Several defense attorneys filed RTKL requests to Centre County for electronic communications between DA Stacy Parks Miller and local judges; County produced metadata and emails from county servers without notifying Parks Miller.
- Judges obtained a preliminary injunction directing RTKL judicial-record requests to judicial open-records officers; County appealed and Commonwealth Court affirmed that relief in related cases.
- Parks Miller separately sought an injunction, arguing a district attorney’s office is a “judicial agency” under the RTKL, so only financial records need be disclosed. The trial court granted the injunction; the County appealed.
- The Commonwealth Court (en banc) reversed, holding a DA’s office is not a “judicial agency” but rather “related staff”/“county staff” under definitions in the Judicial Code and Rules of Judicial Administration.
- The Pennsylvania Supreme Court granted review and affirmed the Commonwealth Court: district attorneys are not part of the unified judicial system for RTKL purposes and therefore cannot claim the RTKL’s judicial-agency limited-disclosure rule.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a district attorney’s office is a “judicial agency” under the RTKL | Parks Miller: DA offices are part of the “system and related personnel” in Judicial Code/PRJA, thus an office/entity of the unified judicial system and a "judicial agency" | County: DAs are executive/county officers; definitions of “system and related personnel” do not make them judicial agencies; RTKL provisions (e.g., DA appeals officer for criminal records) confirm distinct role | Held: DA offices are not judicial agencies under the RTKL; they are "related staff"/county officers and must follow ordinary RTKL disclosure rules |
| Whether borrowing Judicial Code/PRJA definitions to interpret RTKL is appropriate | Parks Miller: Judicial Code/PRJA definitions include DAs in “system and related personnel” and AOPC authority references support inclusion | County: Inclusion in administrative definitions does not convert executive/county officers into judicial agencies; separation-of-powers concerns | Held: Majority used Judicial Code/PRJA definitions to interpret RTKL and concluded DAs are not personnel of the unified judicial system; concurrence agreed with result but objected to relying on those definitions |
| Whether treating DAs as judicial agencies would create constitutional or practical problems | Parks Miller: being part of the judicial system is administrative and does not confer judicial power; participation in the system justifies inclusion | County: Would violate separation of powers and produce absurd results (Attorney General subject to full disclosure but local DAs only to limited judicial disclosure) | Held: Court agreed such a classification would be absurd and raise separation-of-powers concerns (concurrence emphasized this point) |
| Scope of RTKL disclosure for records involving courts and DAs | Parks Miller: broader RTKL protections for judicial agencies should apply to DA records | County: RTKL treats judicial agencies differently; DA records should be subject to standard RTKL presumptions unless otherwise exempt | Held: DA offices are not judicial agencies; their records are governed by ordinary RTKL presumptions (not limited to financial records) |
Key Cases Cited
- Mooney v. Temple Univ. Bd. of Trs., 292 A.2d 395 (Pa. 1972) (recognizing common-law right to inspect public records)
- Wiley v. Woods, 141 A.2d 844 (Pa. 1958) (RTKA enacted to enlarge public examination rights)
- Commonwealth v. Fenstermaker, 530 A.2d 414 (Pa. 1987) (constitutional grounding for public access to judicial records)
- In re Act 147 of 1990, 598 A.2d 985 (Pa. 1991) (invalidating legislative effort to place executive peace officers under judicial branch supervision; separation-of-powers principle)
- In re 2003 Gen. Election for Office of Prothonotary, 849 A.2d 230 (Pa. 2004) (limits on borrowing definitions from Judicial Code/Rules when interpreting other statutes)
- Court of Common Pleas of Lackawanna Cty. v. Pa. Office of Open Records, 2 A.3d 810 (Pa. Cmwlth. 2010) (judicial agencies’ RTKL disclosure limited to financial records)
- Jefferson Cty. Court Appointed Employees Ass’n v. Pa. Labor Relations Bd., 985 A.2d 697 (Pa. 2009) (reaffirming separation-of-powers principles)