Missoula County Public Schools v. Bitterroot Star, 345 P.3d 1035

Addis formerly supervised food services for Missoula County Public Schools, which conducted a 2010 investigation into alleged misconduct and disciplinary action ensued.
Addis left the school position and filed a wrongful discharge suit.
Addis later served as Ravalli County Treasurer after a Ravalli County Commission appointment.
In January 2014, Bitterroot Star, Missoula Independent, and KECI sought release of documents related to Addis’ termination and investigation.
Schools sought an in camera review and balanced privacy interests against the public’s right to know; six documents were ordered released, while others remained private.
Addis appealed the district court’s decision, which the Montana Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether personnel files are public records subject to disclosure.	Addis argues privacy protections render records nonpublic.	Schools contend public body's records fall within right to know; not blanket exemption for personnel files.	Yes; records are not categorically exempt; privacy vs. public disclosure balanced, six documents released.
Whether in camera review was an appropriate method in a non-criminal context.	Addis challenges the process as improper for non-criminal records.	Courts may use in camera review to resolve disclosure disputes in such cases.	Appropriate procedural vehicle to resolve the dispute and determine release.
Whether the district court properly balanced individual privacy against the public’s interest in disclosure.	Addis asserts substantial privacy interests override disclosure.	Public interests in accountability for misuse of public funds outweigh privacy in these records.	Yes; public interest outweighed privacy for records related to misuse of public funds; six documents released.

Bryan v. Yellowstone County Elem. School Dist., 312 Mont. 257 (2002 MT 264) (public-right-to-know analysis applies beyond formal 'public writings'.)
Becky v. Butte-Silver Bow School District No. 1, 906 P.2d 193 (1996) (public records require balancing privacy and disclosure.)
Billings Gazette v. City of Billings, 362 Mont. 522 (2011 MT 293) (personnel files not immune from disclosure when public trust applies.)
Billings Gazette v. City of Billings, ? (2013 MT 334) (fact-specific privacy/public-disclosure balancing.)
Havre Daily News v. City of Havre, 142 P.3d 864 (2006 MT 215) (privacy expectations reasonable when considering public-trust factors.)