Bryan v. Yellowstone County Elementary School District No. 2 was a case before the Montana Supreme Court in 2002 concerning the applicability of open records laws to private corporations.
This case established a number of important precedents:
- Advisory boards, created to serve a public purpose, are public bodies subject to the Montana Public Records Act.
- Decision-making processes which are directly affected by violations of the right to know/participate can be voided by court action.
- In the summer of 2000, aware of major budget cuts for the following year, the Yellowstone County Elementary School District No. 2 directed a committee composed of principles to begin examining alternatives tot he current system which would maintain a propert student-teacher ratio, but would nonetheless cut cost.
- On February 12, the committee submitted its report to the school board
- After submitting the proposal the committee was reformed, with additional members added. The new Reconfiguration Committee was tasked with developing plans for implementing the solutions that the Principles Committee proposed.
- On March 5, 2001, the school board created a third committee with similar membership whose task was to determine logistics and implementation for school closures.
- In the one month between its creation and its report due date, the committee met 8 times. Through these meetings, the committee developed a spreadsheet with a rating system to determine which school were the most efficient and which should be closed.
- On March 29, 2001, the board hosted a public meetings concerning plans for accounting for the budget deficits. At this meeting, a copy of the spreadsheet was handed out, but did not include the rating system designed to help determine which schools to close.
- Then, on April 2, 2001, the Facilities Committee reported to the board and recommended two closure plans involving the closure of up to 3 schools. The school board announced the decisions and announced a meeting for April 9 to get public feedback before commencing with the school closures.
- The Coalition of Rimrock Parents (one of the schools that was to be closed), including Bryan, began to campaign to prevent the closure of the school. In preparing for its arguments, the coalition requested a head to head comparison of the schools, including the criteria the facilities committee used for determining which schools should close.
- The school board denied any knowledge of such a comparison. Then, after hearing a member of the Committee discuss the spreadsheet on the news, the Coalition resubmitted its request, which was again denied.
- At the final meeting about school closures, the spreadsheet, including points system, was again distributed to the city council members and not the public. The final vote was taken and the spreadsheet was not distributed to th e public until after.
- On May 8, 2001, Bryan filed a suit in court, seeking to compel the district to abide by the open records and open meetings laws including the release of all documents related to the committee's search and to void the decision made to close the school.
- The court ruled in favor of the school district and Bryan appealed the decision.
Ruling of the court
The trial court ruled in favor of the school district, ordering that the records could remain sealed.
The Court of Appeals overturned the decision of the trial court and ruled in favor of Bryan. The court first established that Bryan was qualified to file suit despite the fact that she did not submit the original records request because she had a vested interest in the outcome and had worked on the project as a collaborative effort. Next, citing Common Cause v. Statutory Committee, the court reiterated its definition of public body as "a group of individuals organized for a governmental or public purpose". The court went on to determine that the task of deciding which schools would close was clearly a governmental function which was delegated to the committee. This governmental function brought the committee under the definition of public body and thus under the public records law. The court went on to cite, Becky v. Butte-Silver Bow Sch. Dist. 1, to establish the definition of public writings "to mean documents generated or maintained by a public body which are somehow related to the function and duties of that body." Based on this definition the court established that the document in question was a public writing because it was created in order to aid the public body in one of its specified public functions. Finally the court established that Bryan and the Coalitions failure to name the specific document did not constitute a reason for the district to reject the request. Based on these factors the court determined that the school district violated the public's right to know. The court further established that the right to participate inherently hinges on the right to know, because the right to participate requires that the public be well informed on the issues in which they are sharing their voice. Finally the court determined that the violation of the public's right to know and participate, despite its unintentional nature, "tainted" the entire decision making process, and thus decided to void the decision of the school board. Based on this final decision, the court decided to remand the decision back to the school board for an additional hearing once all the pertinent documents are released.