FREEDOM OF INFORMATION COMMISSION
OF THE STATE OF CONNECTICUT
In the Matter of a Complaint
by FINAL
DECISION
Donald H. Schiller and The
Meriden Record Co.,
Complainants,
against Docket
#FIC 87-83
Meriden Board of
Education,,President, Meriden Board of Education, and Meriden Superintendent of
Schools,
Respondents August
23, 1989
The above-captioned matter was heard as a contested case
on April 29, 1987, at which time the complainants and the respondents appeared,
stipulated to certain facts and presented testimony, exhibits and argument on
the complaint. Per order of the
Superior Court (Corrigan, J.) in its March 1, 1989 Memorandum of Decision, the
hearing was reopened on July 11, 1989, at which time the parties again appeared
and presented additional testimony, exhibits and argument on the complaint.
After consideration of the entire record, the following
facts are found and conclusions of law are reached:
1. The
respondents are public agencies within the meaning of §1-18a(a), G.S.
2. By letter
dated February 17, 1987, the complainants asked the respondents to provide
copies of the following records:
a. any complaints filed against Robert
Sorensen, a Meriden teacher;
b. the results of the respondent board's
investigation of the complaints;
c. the minutes of the respondent board's
meeting about Mr. Sorensen's resignation;
d. and Mr. Sorensen's letter of resignation.
3. The
complainants received the records described in paragraphs 2c and d, above.
Docket #FIC 87-83 Page
Two
4. The records
described in paragraph 2b, above, do not exist.
5. The
respondents made a timely oral denial of the complainants' request for the
records described in paragraph 2a, above, and formalized their denial in a
letter dated March 9, 1987.
6. By letter of
complaint dated March 24, 1987, and filed with the Commission on March 25,
1987, the complainants appealed to the Commission from the respondents' denial.
7. The
respondents claim the records in question are exempt from disclosure under
§1-19(b)(2), G.S., as personnel or similar files the disclosure of which would
constitute an invasion of privacy. The
respondents claim the privacy of both the teacher and those who complained
about him would be invaded.
8. The
respondents further claim that to the extent those who complained were
students, records of their complaints are prohibited from disclosure as
educational records under 20 U.S.C. 1232g, commonly called the Buckley
Amendment.
9. The
respondents also claim that the records are exempt from disclosure under
§10-151c, G.S., as teacher evaluation and performance records.
10. On both
hearing dates the respondents offered the records in question for in camera
inspection by the Commission. On April
29, 1987 the hearing officer declined the offer. On July 11, 1989 the hearing officer accepted the records for in
camera inspection by the Commission, per order of the Superior Court.
11. It is found
that the records in question are public records within the meaning of
§1-18a(d), G.S.
12. It is found
that these records are part of the personnel file of a public employee and
pertain to that employee's public employment.
13. It is also
found that the subject teacher, who voluntarily chose to serve the public and
be paid with public funds, has very limited personal privacy rights in matters
pertaining to his public employment.
14. It is found
that there is a legitimate public interest in the disclosure of records about
its employee in matters pertaining to his employment.
Docket #FIC 87-83 Page
Three
15. It is found
more specifically that the records in question are written complaints by public
school students about a teacher.
16. It is found
that the complaints contain allegations about the teacher that were not investigated
by the respondents.
17. It is found,
however, that the subject teacher chose to resign before the respondents began
any formal investigation or termination proceedings.
18. It is found
that there is a heightened public interest in the disclosure of these records
about its employee since he was entrusted with the education and welfare of
children.
19. It is found
that the public interest in disclosure is further heightened since the records
are complaints filed by the very children with whom this employee was
entrusted.
20. It is found
that the public interest is also heightened since the teacher forfeited his
livlihood rather than have the complaints investigated.
21. Thus it is
concluded that the legitimate public interest in disclosure of the records in
question clearly outweighs any limited privacy interest of the subject of those
records.
22. It is
concluded, therefore, that with respect to the teacher and the substance of the
complaints the requested records are not exempt from disclosure under
§1-19(b)(2), G.S.
23. It is found
that the complainants are not seeking the identities of the students.
24. It is further
found that disclosure of the students' identities would invade their personal
privacy.
25. Although not
specifically claimed, the Commission notes that the indentities of those
students may be exempt from disclosure under §1-19(b)(11), G.S.
26. It is also
found that the Buckley Amendment's prohibition against disclosure of records is
not compulsory or mandatory, but merely a condition precedent to the granting
of federal funds to educational institutions.
27. It is
concluded, therefore, that the records in question are not exempt from
disclosure under 20 U.S.C. 1232g.
Docket #FIC 87-83 Page
Four
28. It is found
that the records described in paragraph 2a, above, do not constitute teacher
evaluation and performance records within the meaning of §10-151c, G.S.
29. Thus it is
concluded that the requested records are not exempt from disclosure under §10-151c,
G.S.
30. It is also
concluded that the respondents violated §§1-15 and 1-19(a), G.S., by denying
the complainants' request for copies of the complaints against the teacher with
information identifying others redacted.
The following order by the Commission is hereby
recommended on the basis of the record concerning the above-captioned
complaint:
1. The
respondents forthwith shall provide the complainants with a copy of the
documents described in paragraph 2a, above.
2. The
respondents shall redact, mask or otherwise conceal any and all information
that identifies persons other than the subject of the complaints, Mr. Sorensen.
3. The
respondents henceforth shall act in strict compliance with §§1-15 and 1-19(a),
G.S.
PURSUANT TO 4-180(c) C.G.S
THE FOLLOWING ARE THE NAMES OF EACH PARTY AND THE MOST RECENT MAILING ADDRESS,
PROVIDED TO THE F.O.I.C., OF THE PARTIES OR THEIR AUTHORIZED REPRESENTATIVE.
THE PARTIES TO THIS
CONTESTED CASE ARE:
DONALD H. SCHILLER AND THE
MERIDEN RECORD CO.
Crown Street Square
Meriden, CT 06450
BOARD OF EDUCATION,
PRESIDENT, MERIDEN BOARD OF EDUCATION AND
MERIDEN SUPERINTENDENT OF
SCHOOLS
c/o Thomas N. Sullivan,
Esquire
Sullivan, Lettick &
Schoen
646 Prospect Avenue
Hartford, CT 06105
MERIDEN FEDERATION OF
TEACHERS
c/o James Ferguson, Esquire
McWeeny and Ferguson
638 Prospect Avenue
Hartford, CT 06105
Approved by order of the Freedom of Information
Commission at its regular meeting of August 23, 1989.
Tina
C. Frappier
Acting
Clerk of the Commission