Hallas v. FOIC was a case before the Connecticut Court of Appeals in 1989 concerning the applicability of open records law to individuals contracted by public agencies.
This case affirmed the decision of Board of Trustees of Woodstock Academy v. FOIC and emphasized that all 4 points must be met for an organization to be considered a public body.
- Robinson and Cole is a law firm located in the city of Hartford. They have acted as the bonds counsel for the town of Windsor since 1967.
- On February 12, 1985, Hallas submitted a records request to the firm seeking to inspect documents relating to bonds issued by the city between 1966-1983.
- The firm denied the request, claiming, "(1) certain documents were protected from disclosure because of the attorney-client privilege, (2) the firm was not the proper place to make their request, and (3) the documents were not public records."
- The Connecticut Freedom of Information Commission and the trial court ruled in favor of the firm.
- Hallas appealed the decisions.
Ruling of the court
The Connecticut Freedom of Information Commission and the trial court ruled in favor of the law firm, finding that it did not meet the four part test established by Board of Trustees of Woodstock Academy v. FOIC.
The Supreme Court affirmed the decision of the trial court, granting judgment in favor of the law firm. The court cited Board of Trustees of Woodstock Academy v. FOIC, stating that any organization must meet all four criteria in order to be considered a public body under the law. The court went on to find that the law firm was not in any way regulated more heavily due to its duties than any other state law firm. Thus, the firm failed one portion of the test and could not be considered a public body.