California State University, Fresno Assn., Inc. v. Superior Court was a case before California's Fifth District Court of Appeal in 2001 concerning donor anonymity and the definition of public agency.
This case established that auxiliary associations that act on behalf of public universities are not in themselves public bodies and are therefore not subject to public records requests.
- California State University, Fresno proposed building a new 103 million dollar arena. The funding for the arena would come from primarily private donors and it would be managed by a university affiliated non-profit, the California State University, Fresno Association, Inc. (Association). The majority of the funds collected came through donations in exchange for luxury suits in the new arena. Some of the individuals who donated requested to remain anonymous.
- On October 14, 1999, The McClatchy Company or the Fresno Bee, under the California Public Records Act requested the records of those who had donated a received luxury suits.
- On October 22, 1999, the University rejected the request based on statute 6255, arguing that the detriment to public interest in form of the University's inability to receive future donations weighs against the public interest in disclosure of the records.
- The McClatchy Company filed suit on March 24, 2000, and the lower court ruled on December 19, 2000 in favor of McClatchy, ordering the documents released.
- The University and the Association appealed in January 2001. The University argued that the records were not public documents while the Association argued that typically California Courts have not recognized axillary organizations as public bodies.
Ruling of the court
The trial court ruled in favor of McClatchy and ordered the list of all donors and the contracts for the luxury suits held by both the University as well as the Association because the University and the Association because it is under the control of the university are considered public bodies and that neither party convincingly argued that it was in the public's interest to withhold the documents. Further, the licenses for luxury suits are not true charitable donations as the licensees will be receiving considerable benefit from their donation.
The court of appeals delivered a split decision ordering the University to disclose the documents but allowing the Association to retain the documents as exempt.
The court of appeals argued that the documents in question were in fact public records, citing Braun v. City of Taft, which provided an expansive definition of records to include all documents held by the public which are important for the administration of public duty. They further held that the documents are not exempt based on California's catch all exemption of statute 6255 because the public interest in the business of the government is high and that the promise of confidentiality was not made and that disclosure should not hinder the Universities ability to collect future donations.
They, however, could find nothing in California law which indicated whether axillary agencies were considered public bodies under the CPRA and thus turned to litigation from other states for advice. The court found split decision, citing a number of cases including:
However, the court determined that these cases could not apply because each of these states defined public body much more broadly than California. The court thus turned to the statute itself and determined that the limited nature of the CPRA's definition of public body leads them to declare that the Association is not a public body and therefore not subject to public records requests.
- ↑ Ruling of the Court
- ↑ 2.0 2.1 2.2 Ruling of the Court