S. Parks Miller, DA v. County of Centre
135 A.3d 233
| Pa. Commw. Ct. | 2016Background
- Centre County responded to RTKL requests for telephone usage records (Verizon invoices) showing calls between DA Stacy Parks Miller and local judges; County released partial numbers and a usage spreadsheet.
- DA Miller sought a preliminary injunction declaring DA records "judicial records" and enjoining the County from responding to RTKL requests about the DA or DA’s Office.
- The trial court, relying on its prior rulings in related Judicial Cases, issued two preliminary injunctions: (May 13) barring the County from responding to RTKL requests for judicial records relating to the DA; and (May 19) prohibiting production of any emails or letters to or from the DA’s Office.
- The County appealed both injunctions to the Commonwealth Court, arguing the DA’s Office is not a "judicial agency" under the RTKL and that the May 19 injunction was overbroad as to content.
- The DA argued the DA and staff qualify as judicial personnel, and that much correspondence is protected under CHRIA as criminal investigative material.
- The Commonwealth Court reversed both trial-court orders, holding the DA’s Office is not a judicial agency and that the content-based injunction was unsupported and overbroad.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the DA’s Office is a "judicial agency" under the RTKL | Miller: DA and staff are part of the unified judicial system; thus their records are "judicial records" outside County's RTKL authority | County: DA’s Office is not a court or court-supervised personnel; DA and staff are county officers/related staff subject to County RTKL responses | The DA’s Office is not a judicial agency; injunction based on that premise reversed |
| Whether the trial court properly enjoined production of all emails/letters to/from DA’s Office | Miller: Most correspondence relates to criminal investigations and is protected by CHRIA | County: The injunction is overbroad; CHRIA protection must be shown case-by-case | The content-based injunction is overbroad and unsupported; reversed; County should consult DA when CHRIA may apply |
Key Cases Cited
- Court of Common Pleas of Lackawanna Cnty. v. Office of Open Records, 2 A.3d 810 (Pa. Cmwlth. 2010) (held records produced by court-supervised employee were records “of” a judicial agency)
- Rosenwald v. Barbieri, 462 A.2d 644 (Pa. 1983) (construed "related staff" as those aiding the judicial process but not court-supervised)
- Beckert v. Warren, 439 A.2d 638 (Pa. 1981) (explains limits on court supervisory authority over county staff)
- County of Luzerne v. Luzerne County Retirement Board, 882 A.2d 531 (Pa. Cmwlth. 2005) (standard for reversing trial court legal error in preliminary injunction decisions)
- Seeton v. Adams, 50 A.3d 268 (Pa. Cmwlth. 2012) (describes prosecutorial functions of district attorneys and limits to mandamus against discretionary prosecutorial decisions)