Connecticut Public Records: Notable Case Law
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Town of Avon v. Sastre, 224 Conn. App. 155, 312 A.3d 40 (2024) | Appeals court held that FOIC had correctly determined that records regarding the 2019 resignation/retirement of the town’s police chief were in fact public. The test for presumptively public records is that 1) document relates to “the conduct of the public’s business” and 2) was “prepared, owned, used, received, or retained by a public agency.”
Comm’r of Emergency Servs. & Pub. Prot. v. Freedom of Info. Comm’n, 330 Conn. 372, 194 A.3d 759 (2018) | Documents related to search and seizure following elementary school shooting are public records because “there was probable cause to believe the documents constituted evidence of a criminal offense related to the conduct of the public’s business.”
Hartford Courant Co. v. Freedom of Info. Comm’n, 261 Conn. 86 (2002) | When an agency cannot adequately separate exempt data from nonexempt data, the agency must either develop a program or contract with an outside entity to develop a program, as long as the requesting party bears the cost.
Board of Trustees v. Freedom of Information Comm’n, 181 Conn. 544 (1980) | When determining whether an institution is a public body for purposes of the FOIA, courts review the following criteria: (1) whether the entity performs a governmental function; (2) the level of government funding; (3) the extent of government involvement or regulation; and (4) whether the entity was created by the government.
Wilson v. Freedom of Information Comm’n, 181 Conn. 324 (1980) | An agency claiming an exemption to the FOIA bears the burden of demonstrating its applicability.