Padgett v. Pennsylvania State Police
2013 Pa. Commw. LEXIS 313
| Pa. Commw. Ct. | 2013Background
- Requester sought PSP records under RTKL including a Williamsport police report and related materials related to Bradford County cases 97-CR-768 and 97-CR-000888.
- PSP identified records responsive to part 1; disclosed part 1; denied part 2 citing the criminal investigative exception and CHRIA, and other RTKL exemptions.
- OOR dismissed the appeal for non-compliance with Section 1101(a) for failing to state records are public or address agency denial grounds.
- Requester appealed to OOR; argued the Williamsport police report is not exempt and is exculpatory evidence; claimed records are public and necessary for due process and fair trial.
- Court reviewed the sufficiency of the appeal under Section 1101(a) and concluded the appeal was legally insufficient and properly dismissed by OOR.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the appeal sufficiently stated grounds under RTKL 1101(a) | Padgett argued records are public; exemptions not explained | Padgett failed to address agency denial grounds or show records public | Yes; petition rejected for insufficiency |
| Whether requester addressed exemptions including CHRIA | Padgett did not adequately discuss CHRIA or exemptions | PA PSP exemptions cited; requester did not engage with them | Yes; failure to address exemptions supports dismissal |
| Whether length of fixable procedural defects precludes review | N/A | N/A | Yes; minimal pleading required under 1101(a) not met |
Key Cases Cited
- Saunders v. Dep’t of Corr., 48 A.3d 540 (Pa.Cmwlth.2012) (prescribes sufficiency of 1101(a) pleading to challenge denial)
- Dep’t of Corr. v. Office of Open Records, 18 A.3d 429 (Pa.Cmwlth.2011) (requires addressing grounds for denial in appeal)
- Coulter v. Pa. Bd. of Prob. & Parole, 48 A.3d 516 (Pa.Cmwlth.2012) (identity of requester not relevant to RTKL access)
- Bowling v. Office of Open Records, 990 A.2d 813 (Pa.Cmwlth.2010) (scope of review on OOR orders; independent review by court)