Angelo Iafrate Constr., L.L.C. v. State of Louisiana was a case 2004 before the Louisiana First Circuit Court of Appeal concerning construction bids.
This case established that if a constitutional right to privacy could be established for personal records, the exemption protecting those personal records must be weighed against the public interest in the release of those records to determine if they are truly exempt.
- Angelo Iafrate Construction is a highway construction company. The company, in order to comply with Federal law, must submit payroll records to the state Department of Transportation (DOTD) including the names, addresses, social security numbers, and job details including wages, hours worked and job descriptions. This is designed to insure fair wage practices
- The International Union of Operating Engineers submitted a records request for all of this information from one particular job.
- The DOTD agreed to release all the information but the names addresses and social security numbers of the employees.
- Iafrate, fearing the DOTD might change heart and release the information, filed suit seeking to prevent the release of the information.
- The trial court ruled in favor of Iafrate, sealing the documents in question.
- The union appealed the decision.
Ruling of the court
The trial court ruled in favor of Iafrate, ordering the documents sealed. The court felt that the employees interest in privacy outweighed any public interest in the documents. The court further held that the DOTD held the documents for investigative purposes, thus exempting the documents under Louisiana Public Records Act statute 44:4(3) which exempts records held by state investigatory agencies.
The Court of Appeals affirmed the ruling of the trial court, ordering the documents exempt.
The Court of Appeals first determined that statute 44:4(3) which exempted information from investigatory agencies was designed to protect trade secrets and did not apply to the DOTD, as their function was not primarily investigatory. The court went on to determine that the balancing test for determining if the employees had a constitutional right to privacy was absolutely appropriate. The court further held that the employees did possess a right to privacy of their home address information when coupled with the financial information present in the documents. The court finally determined that because the DOTD had agreed to release all the information necessary for insuring compliance with wage law, the public had little to no interest in the names and addresses of the individual employees. Based on all of these facts, the courts affirmed the decision of the trial court and ordered the documents exempt.
- ↑ 1.0 1.1 1.2 Ruling of the Court