Laborers Int'l Union Local No. 374 v. City of Aberdeen was a case before the Washington Court of Appeals, Second Division in 1982 concerning the personal privacy exemptions.
This case established a number of important precedents:
- That monitoring pay rates of private contractors for compliance with federal wage law constitutes a public function of government agencies.
- That individuals on payroll possess no right of privacy for their names.
- In 1979 the City of Aberdeen awarded a contract to Felton Construction Co. to repair the cities sewers.
- The project was partially federally funded, so the contractor was required to submit payroll records to the city to insure that the construction firm followed federal wage laws.
- The labor union, representing the employees of Felton Construction Co., requested copies of the payroll records from the company to insure proper pay rates as well. The construction company denied the request.
- The union then submitted a public records request to the city for the same payroll documents. The city complied, but redacted individual names to protect privacy.
- The Union noticed a difference between the hours listed on the payroll records and those listed on welfare insurance premium forms.
- They filed suit, requesting the full records.
- The trial court sided with the city and determined that the names were properly redacted.
- The decision was appealed.
Ruling of the court
The trial court ruled in favor of the city, determining that the records in question were in fact public records and the names were properly redacted to protect privacy interests.
The Union and the construction company appealed the decision. The union continued to press for the full records, while the company wished to have the payroll records declared not public.
The [[Washington Court of Appeals#Division 2|Washington Court of Appeals, Second Division] reverse the decision of the trial court, ruling instead in favor of the union. The court first established that the records in question were in fact public records. It determined that the city of Aberdeen was in fact a local agency and the records in question were in fact public records because they were being held in order to perform the governmental function of monitoring the construction company to insure compliance with federal wage law. The court also rejected the construction companies allegations that the documents fell under exemptions for investigative materials, determining that the city was not an investigative body, nor was i conducting a specific investigation. In addition, citing Hearst Corp. v. Hoppe, the court determined that the names in question were not exempt for privacy reasons as their release was not unreasonable and their release was clearly within the public interest. Based on these determinations, the court ordered the full release of the documents in question, ruling in favor of the union.