W. Lawson v. Philadelphia Clerk of Courts
1917 C.D. 2014
| Pa. Commw. Ct. | Oct 20, 2016Background
- Petitioner William Lawson filed a Right-to-Know Law (RTKL) request with the Philadelphia Clerk of Courts for a certified copy of his sentencing order (CP-51-CR-0609631-1997).
- The Clerk responded by sending a bill of information, which Lawson contended did not satisfy his RTKL request.
- Lawson appealed to the Office of Open Records (OOR), claiming the Clerk failed to respond; the OOR dismissed the appeal with prejudice for lack of jurisdiction because the Clerk is a judicial agency.
- Lawson sought review in the Commonwealth Court, which reviewed OOR jurisdiction de novo and applied recent precedent treating clerks as part of the unified judicial system.
- The Court affirmed the OOR dismissal, holding judicial agencies (including clerks of courts) are outside OOR jurisdiction and noting sentencing orders are not public records under the RTKL (though accessible by other means).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether OOR has jurisdiction over records requests to the Clerk of Courts | Lawson: Clerk is subject to RTKL and OOR review | Clerk/OOR: Clerk is a judicial agency and not subject to OOR jurisdiction | OOR lacks jurisdiction; dismissal affirmed |
| Whether the bill of information satisfied the RTKL request for a sentencing order | Lawson: Bill of information is insufficient; he is entitled to the sentencing order | Clerk: (implicit) RTKL does not govern judicial records like sentencing orders | Even if jurisdiction existed, sentencing orders are not "public records" under RTKL; RTKL access is limited for judicial agencies |
| Whether Lawson has a liberty interest warranting RTKL relief or release | Lawson: Liberty interest in obtaining sentencing order; alleged improper incarceration without order | Respondent: RTKL is not the vehicle to collaterally attack conviction or resolve incarceration legality | Court: Liberty-interest argument is not resolved via RTKL; RTKL cannot be used to collaterally attack conviction |
| Whether OOR erred in dismissing appeal with prejudice | Lawson: OOR derelict; duty to ensure access to public records | OOR: Properly dismissed due to lack of jurisdiction over judicial agencies | Dismissal affirmed as jurisdictional; OOR acted properly |
Key Cases Cited
- Faulk v. Philadelphia Clerk of Courts, 116 A.3d 1183 (Pa. Cmwlth. 2015) (establishes that clerks/judicial agencies are outside OOR jurisdiction and limits RTKL access to certain judicial records)
- Commonwealth v. Fenstermaker, 530 A.2d 414 (Pa. 1987) (discusses common-law public access to criminal courts and records)
- Sturgis v. Department of Corrections, 96 A.3d 445 (Pa. Cmwlth. 2014) (rejects liberty-interest claims based on non-existence of sentencing order via RTKL)
- Guarrasi v. Scott, 25 A.3d 394 (Pa. Cmwlth. 2011) (RTKL not a vehicle for collateral attack on convictions)
- League of Women Voters of Greater Pittsburgh v. Allegheny County, 819 A.2d 155 (Pa. Cmwlth. 2003) (clerks of court are personnel of the unified judicial system)