432 P.3d 910
Wyo.2019Background
- Jackson Hole Airport Board (Board) is a five-member joint powers board created by Town of Jackson and Teton County to operate Jackson Hole International Airport; board members are jointly appointed by the town and county.
- In 2017 the Board considered purchasing the sole fixed base operator (FBO) and acting as the Airport’s FBO; Wyoming Jet sought records about that decision under the Wyoming Public Records Act (WPRA).
- The Board denied it was subject to the WPRA, produced some materials, and withheld others citing confidentiality and burden.
- Wyoming Jet sued in district court seeking disclosure; Board counterclaimed that only the Special District Public Records and Meetings Act (Special District Act) applies and limits disclosure to certain listed documents.
- The district court granted summary judgment for the Board, concluding the Special District Act governs and that the Board was not a "political subdivision" for WPRA purposes.
- The Wyoming Supreme Court reversed, holding the Special District Act does not supplant the WPRA and the Board is subject to WPRA disclosure obligations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Jackson Hole Airport Board is subject to the WPRA | Wyoming Jet: Board is a public entity whose records created in furtherance of public business are subject to the WPRA | Board: Special District Act controls record obligations for covered entities and limits disclosure to listed documents; Board is not a political subdivision | Court: Reversed — Special District Act supplements access by ensuring certain copies are available but does not replace WPRA; WPRA governs disclosure |
| Whether §16-12-303(a) of the Special District Act limits the universe of records a covered entity must disclose | Wyoming Jet: §303(a) lists documents to be made available but does not narrow WPRA disclosure | Board: §303(a) identifies the records entities must maintain and thus limits disclosure obligations | Court: §303(a) requires certain documents be kept and made readily available but does not displace existing record-retention statutes or the WPRA’s broader disclosure requirements |
| Whether joint powers airport boards qualify as "special districts"/political subdivisions under the WPRA | Wyoming Jet: Board performs a local public function in a geographic area and fits the ordinary meaning of special district; WPRA should be liberally construed in favor of disclosure | Board: Precedent requires three "badges" (taxing power, elected officers, defined boundaries); Board lacks these, so not a political subdivision for WPRA | Court: Board is a special district for WPRA purposes; the narrower constitutional/contract contexts do not control legislative intent in the WPRA; applying WPRA avoids absurd results |
| Whether conflicts between the Special District Act and the WPRA require treating the Special District Act as controlling | Wyoming Jet: Where conflict exists, the Special District Act itself says WPRA controls; legislature intended harmony | Board: Specificity of Special District Act means it should control over general WPRA | Court: Rejects preclusive reading of Special District Act; statute expressly preserves WPRA as controlling when conflicts arise, so WPRA governs disclosure |
Key Cases Cited
- Weston Cty. Hosp. Joint Powers Bd. v. Westates Constr. Co., 841 P.2d 841 (Wyo. 1992) (discusses "badges" of a political subdivision in a different legal context)
- Witzenburger v. State ex rel. Wyoming Community Development Authority, 575 P.2d 1100 (Wyo. 1978) (definitional test for "political subdivision" referenced by courts)
- PacifiCorp, Inc. v. Wyo. Dep't of Revenue, 401 P.3d 905 (Wyo. 2017) (rules of statutory interpretation and in pari materia construction)
- Powder River Basin Res. Council v. Wyo. Oil & Gas Conservation Comm'n, 320 P.3d 222 (Wyo. 2014) (liberal construction of WPRA in favor of disclosure)