Napata v. University of Maryland Medical System Corp.
12 A.3d 144
Md.2011Background
- UMMS sought records from a private, non-profit state instrumentality; UMMS denied disclosure citing lack of PIA applicability.
- The Maryland Public Information Act (PIA) applies to public records of state units or instrumentalities, subject to statutory exemptions.
- The Legislature created UMMS by transferring University assets to a private entity, but retained substantial state oversight and control.
- UMMS's enacting statute (Education Article §13-303(a)(2)) expressly provides UMMS shall not be a state agency or subject to laws affecting only governmental or public entities.
- Court of Special Appeals affirmed dismissal, holding UMMS exempt from PIA by statute, with Napata petitioning for certiorari.
- The Court granted certiorari to resolve whether UMMS is a state instrumentality and, if so, whether the statutory exemption removes it from the PIA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether UMMS is a State instrumentality for PIA purposes. | Napata argues UMMS is a state instrumentality subject to the PIA. | UMMS contends it is a state instrumentality but exempt from the PIA by statute. | UMMS is an instrumentality, but exempt from the PIA by its statute. |
| Whether the Ed. §13-303(a)(2) exemption applies to UMMS and shields it from the PIA. | Napata contends exemption does not apply to shield PIA disclosure. | UMMS argues exemption applies because PIA is a law affecting governmental/entities. | UMMS is exempt from the PIA due to the express statutory exemption. |
| Whether 2007 legislative history supports maintaining UMMS exemption from PIA. | Napata cites legislative intent to subject UMMS to PIA. | Legislative history shows rejection of proposed amendment; supports exemption. | Legislative history corroborates exemption; no contrary implication. |
Key Cases Cited
- City of Baltimore Development Corp. v. Carmel Realty Assocs., 395 Md. 299, 910 A.2d 406 (Md. 2006) (comprehensive analysis of instrumentality status under PIA)
- Moberly v. Herboldsheimer, 276 Md. 211, 345 A.2d 855 (Md. 1975) (hospital/municipal linkage supports instrumentality status)
- Mezzanote v. Md. Ins. Guaranty Ass'n, 297 Md. 26, 464 A.2d 1068 (Md. 1983) (factors establishing state instrumentality for PIA applicability)
- Andy's Ice Cream, Inc. v. City of Salisbury, 125 Md. App. 125, 724 A.2d 717 (Md. Ct. App. 1999) (zoo commission as instrumentality of city under PIA)
- State v. Bell, 351 Md. 709, 720 A.2d 311 (Md. 1998) (legislative history as interpretive guide to statutory intent)