Uniontown Newspapers, Inc., d/b/a The Herald Standard and C. Haines v. PA Dept. of Corrections
151 A.3d 1196
| Pa. Commw. Ct. | 2016Background
- Requester (Uniontown Newspapers/Christine Haines) sought aggregated data about inmate diagnoses at SCI‑Fayette; OOR ordered DOC to disclose “all responsive records” (final determination) and DOC did not appeal.
- DOC initially argued multiple RTKL exemptions (medical records and noncriminal investigation among others); OOR rejected those defenses and directed disclosure within 30 days.
- DOC produced some aggregated statistics and later produced additional materials, but Requester contended numerous responsive records remained undisclosed (databases, mortality lists, contractor pharmacy reports, investigation emails).
- Requester filed an enforcement petition seeking compliance with OOR’s order and sanctions; DOC denied noncompliance and argued its narrower construction of the Request excluded inmate medical files.
- The Commonwealth Court held this is an enforcement action limited to whether DOC complied with OOR’s unappealed Disclosure Order (scope defined by OOR’s construction), found genuine disputes of material fact about undisclosed pre‑existing and investigation‑related records, and resolved that DOC need not disclose individual inmate medical files or create new compilations from those files.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of Disclosure Order / Request interpretation | Requester: OOR construed request as aggregated, non‑identifying diagnostic data; DOC must disclose those data. | DOC: Request requires review of medical files to determine whether inmates “contracted” illnesses at SCI‑Fayette; thus much data is exempt or not responsive. | Court: OOR’s construction controls; DOC’s narrow interpretation rejected. Aggregated diagnoses by type/number are within the Disclosure Order. |
| Whether DOC complied / produced all responsive records | Requester: DOC withheld pre‑existing records (PTrax, Oncology DB, Mortality Lists, Contractor Reports) and investigation emails; DOC failed good‑faith search. | DOC: It provided all responsive records in its possession and reasonably construed the Request; no further records exist. | Court: Genuine issue of material fact exists as to whether DOC produced all responsive pre‑existing and investigation‑related records; case proceeds to trial for fact‑finding. |
| Disclosure of individual inmate medical files / duty to compile data | Requester: Medical files are source material and should be produced in redacted form or used to compile aggregate data. | DOC: Individual medical files are exempt and agency need not create new compilations from files. | Court: Inmate medical files are exempt under RTKL §708(b)(5); DOC need not disclose them (even redacted) or create new compiled records from them. Judgment for DOC on this narrow point. |
| Bad faith / sanctions (attorneys’ fees, civil penalties) | Requester: DOC’s late production, alleged inadequate search, and nondisclosure show bad faith meriting sanctions. | DOC: Any delay was minimal; it cooperated and produced records; no bad faith. | Court: Evidence suggests possible failures (search issues and nondisclosure), but extent unclear; reserved judgment on sanctions pending further fact development. |
Key Cases Cited
- Com. v. Derry Twp., 351 A.2d 606 (Pa. 1976) (unappealed agency order cannot be collaterally attacked in enforcement).
- Bowling v. Office of Open Records, 75 A.3d 453 (Pa. 2013) (RTKL enforcement and sanctions authority of courts).
- Paint Twp. v. Clark, 109 A.3d 796 (Pa. Cmwlth. 2015) (responsive‑record existence measured as of request date).
- Dep’t of Corr. v. Disability Rights Network of Pa., 35 A.3d 830 (Pa. Cmwlth. 2012) (agency not required to create records/compile data from individual files).
- Hodges v. Dep’t of Health, 29 A.3d 1190 (Pa. Cmwlth. 2010) (agency burden to prove nonexistence of records).
- Chambersburg Area Sch. Dist. v. Dorsey, 97 A.3d 1281 (Pa. Cmwlth. 2014) (good‑faith search requirement and remand when agency later finds additional records).
- Smith Butz, LLC v. Pa. Dep’t of Envtl. Prot., 142 A.3d 941 (Pa. Cmwlth. 2016) (court may accept agency affidavits absent evidence of bad faith).
- Carey v. Dep’t of Corr., 61 A.3d 367 (Pa. Cmwlth. 2013) (agency may not construe requests to avoid disclosure of nonexempt records).
- Dep’t of Corr. v. St. Hilaire, 128 A.3d 859 (Pa. Cmwlth. 2015) (medical incident/injury reports distinguished from protected medical files).