Attorney General v. Mystic Valley Regional Charter School

Summary

The Massachusetts Supreme Judicial Court held that Commonwealth charter schools, including Mystic Valley Regional Charter School, are subject to the Massachusetts public records law. The court concluded that such schools qualify as authorities established by the General Court to serve a public purpose under G. L. c. 4, § 7, Twenty-sixth. The court affirmed the Superior Court judgment on the pleadings requiring Mystic Valley to respond to public records requests.

Holdings

1. Commonwealth charter schools, including Mystic Valley, are agencies subject to the Massachusetts public records law and must respond to public-records requests under G. L. c. 66, § 10.
2. A Commonwealth charter school's operational independence and corporate characteristics do not remove it from the public records law.
3. The expressio unius maxim does not exclude Commonwealth charter schools from the public records law where applying it would defeat the statute's evident purpose.
4. Financial burden and interference with educational operations do not excuse compliance with clear statutory disclosure obligations, although the public records law provides mechanisms to mitigate undue burden.

Questions Presented

1. Whether a Commonwealth charter school qualifies as an agency subject to the Massachusetts public records law.
2. Whether a Commonwealth charter school is an authority established by the General Court to serve a public purpose under G. L. c. 4, § 7, Twenty-sixth.
3. Whether the charter school's operational independence, corporate characteristics, limited statutory designations as governmental entities, or asserted compliance burdens exclude it from the public records law.

Disposition

affirmed