Patterson v. Convention Center Authority of the Metropolitan Government
421 S.W.3d 597
| Tenn. Ct. App. | 2013Background
- CCA manages payroll records for convention-center construction under TPRA; records include third-party contractors’ employees’ home addresses and SSNs; petitioners sought unredacted payroll data to study local employment and wage compliance; CCA redacted addresses and SSNs citing privacy and federal guidance; ORC advised records public but uncertain about addresses; trial court ordered unredacted addresses but later stayed pending appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether TPRA explicitly exempts contractor employees’ home addresses | Patterson/Wells: addresses are public records | CCA: addresses are exempt under 10-7-504(f) as “other public employees” or implicitly exempt | Explicit exemption not applied; addresses not exempt |
| Whether contractor employees qualify as 'other public employees' under 10-7-504(f) | Employees are not private; could be public due to project nature | Employees are private contractors’ workers, not public employees | Not public employees; not exempt under 10-7-504(f) |
| Whether TPRA contains an implicit exemption for addresses based on privacy concerns | No blanket implicit exemption; policy favors disclosure | Implicit exemption exists due to privacy and related statutes | No implicit exemption for home addresses under TPRA |
| Whether federal law (FOIA/Davis-Bacon context) guides TPRA interpretation | FOIA balancing should apply | TPRA has no balancing test; FOIA guidance not controlling | FOIA balancing not adopted under TPRA |
| Attorney’s fees and costs on cross-appeal | Should be awarded for willful nondisclosure | Disclosure with redactions in good faith; no willfulness | No abuse of discretion; fee denial affirmed |
Key Cases Cited
- Griffin v. City of Knoxville, 821 S.W.2d 921 (Tenn.1991) (TPRA broadly construed to maximize public access)
- Gautreaux v. Internal Medicine Educ. Found., 336 S.W.3d 526 (Tenn.2011) (TPRA interpreted with broad public-access mandate)
- Schneider v. City of Jackson, 226 S.W.3d 332 (Tenn.2007) (Public-records denial must be supported by statute; limits on policy-based exceptions)
- Memphis Publ’g Co. v. City of Memphis, 871 S.W.2d 681 (Tenn.1994) (Public-records exemptions must be statutory; no broad policy carve-outs)
- Tenn. Dept. of Defense v. Fed. Labor Relations Auth., 510 U.S.487 (1994) (FOIA-based privacy balancing applied in federal context; persuasive but not controlling for TPRA)