Tricia Mezzacappa v. Northampton County

Summary

The Supreme Court of Pennsylvania considers whether mug shots constitute "identifiable descriptions" and therefore criminal history record information under the Criminal History Record Information Act. The Court also addresses whether the Act limits dissemination of such information to State or local police departments and whether privacy interests require a balancing analysis under the Right-to-Know Law. The opinion arises from related appeals involving Tricia Mezzacappa's requests to Northampton County for mug shots.

Holdings

1. A mug shot is an "identifiable description" under Section 9102 of the Criminal History Record Information Act because the phrase encompasses descriptions conveyed through photographs or other depictions, not merely written or spoken descriptions.
2. Under the version of Section 9121(b) in effect when the requests were made, criminal history record information could be disseminated to individuals or noncriminal justice agencies only by a state or local police department upon request; therefore, Northampton County was prohibited from releasing the requested mug shots to Mezzacappa.

Questions Presented

1. Whether a mug shot is an "identifiable description" within the Criminal History Record Information Act's definition of criminal history record information.
2. Whether Section 9121(b) of the Criminal History Record Information Act prohibited Northampton County, a non-law-enforcement agency, from disseminating mug shots to an individual.
3. Whether the case should be remanded for balancing the privacy interests of the mug-shot subjects against the interests in disclosure.

Disposition

reversed