In re Petition of Missoula County Public Schools v. Bitterroot Star, Missoula Independent, KECI, and Valarie Addis

Summary

The Montana Supreme Court affirmed a district court order requiring release of six documents concerning alleged misuse of public money and facilities by a former public school employee. The court held that personnel-file status does not create a blanket exemption from Montana's constitutional right to examine public documents and that the employee's privacy interest was outweighed by the public interest in disclosure. The court also approved the school district's decision to seek in camera review before releasing the records.

Holdings

1. Documents held by a public body are not categorically exempt from public disclosure merely because they are contained in a personnel file.
2. Whether records must be disclosed requires a fact-specific balancing of the individual's privacy interest against the merits of public disclosure.
3. A public body may appropriately initiate a judicial proceeding seeking in camera review and a determination whether individual privacy interests exceed the merits of public disclosure when competing constitutional rights are asserted.
4. The District Court correctly applied Montana law, properly ordered release of the six investigatory documents, and correctly granted summary judgment to the Schools on the media outlets' counterclaim.

Questions Presented

1. Whether documents in Addis's personnel file were categorically exempt from disclosure as nonpublic records.
2. Whether the District Court properly balanced Addis's individual privacy interest against the public's constitutional right to examine documents of public bodies.
3. Whether the Schools acted prudently and properly invoked a judicial in camera review proceeding to resolve the competing disclosure and privacy claims.
4. Whether summary judgment for the Schools on the media outlets' counterclaim was proper.

Disposition

affirmed