FREEDOM OF INFORMATION COMMISSION
OF THE STATE OF CONNECTICUT
In the Matter of a Complaint
by FINAL
DECISION
William M. Laviano,
Complainant,
against Docket
#FIC 88-425
Ridgefield Board of
Education,
Respondent August
23, 1989
The above-captioned matter was heard as a contested case
on January 3, 1989, at which time the complainant and the respondent appeared,
stipulated to certain facts and presented 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 respondent
is a public agency within the meaning of §1-18a(a), G.S.
2. The Commission
takes administrative notice of its final decision and record in Docket #FIC
88-165.
3. It is found
that during the summer of 1988, the complainant requested the respondent
provide him with access to bills it received from its attorneys from April
through June, 1988 for work on matters related to Lodestar, the
Ridgefield high school literary magazine.
4. It is found
that the respondent provided the complainant with photocopies of the bills in
question, with part of each line redacted.
5. It is found
that on October 12, 1988, the respondent's attorney, acting on behalf of the
respondent, orally denied the the complainant access to the bills in their
unredacted form.
6. It is found
that by letter dated October 14, 1988, and filed with the Commission on October
17, 1988, the complainant appealed to the Commission from the denial of his
request.
7. The respondent
claims that the redacted information is legal advice exempt from disclosure
under §1-19(b)(10), G.S., as a communication privileged by the attorney-client
relationship.
Docket #FIC 88-425 Page
Two
8. The respondent
also claims that the redacted information pertains to strategy and negotiations
with respect to pending litigation and is exempt from disclosure under
§1-19(b)(4), G.S.
9. It is found
that the bills list, for each item the respondent is billed for, the date, the
initials of the attorney involved, a few words describing the work done, and
how many hours the work took.
10. It is found
that for each item the information redacted is part of the brief description of
the work done.
11. It is found
that at the time of the hearing on this matter no member of the respondent had
seen the redacted information.
12. It is found,
therefore, that the redacted information did not advise the attorneys' client,
the respondent, on legal matters.
13. It is
concluded that the respondent failed to prove the redacted information was
legal advice containing communications privileged by the attorney-client
relationship.
14. It is
concluded, therefore, that the redacted information is not exempt from
disclosure under §1-19(b)(10), G.S.
15. It is further
found that the few words describing the work done for each item is not a record
pertaining to the strategy and negotiations of the respondent's pending claims
and litigation, but merely an itemized accounting for billing purposes.
16. It is
concluded, therefore, that the redacted information is not exempt from
disclosure under §1-19(b)(4), G.S.
17. It is
concluded that the respondent violated §§1-15 and 1-19(a), G.S., by not
providing the complainant with prompt access to the requested bills in their
entirety.
Docket #FIC 88-425 Page
Three
The following order by the Commission is hereby
recommended on the basis of the record concerning the above-captioned
complaint:
1. The respondent
forthwith shall provide the complainant with a copy of the bills, described in
paragraph 3, above, in their entirety.
2. The respondent
shall cause a copy of the final decision in this matter to be posted at the
Ridgefield town clerk's office for thirty days immediately after receipt of the
notice of final decision.
3. The Commission
reminds the respondent that Commission staff attorneys are available at no cost
to the respondent to answer questions over the telephone and lead workshops on
Freedom of Information Act requirements.
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:
WILLIAM M. LAVIANO, ESQUIRE
24 Bailey Avenue
Ridgefield, CT 06877
RIDGEFIELD BOARD OF
EDUCATION
c/o Robert B. Mitchell,
Esquire
Durant, Sabanosh, Nichols
& Houston
855 Main Street
Bridgeport, CT 06604
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