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Dawson v. State Compensation Insurance Authority
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Dawson v. State Compensation Insurance Authority was a case before the Colorado Court of Appeals in 1990 concerning whether private institutions functioning as public bodies are subject to public records requests.
Important precedents
This case established that the definition of public body should be construed liberally so as to include bodies that were not necessarily in the original definition but clearly fall within the intention of the legislature.[1]
Background
- Dawson requested to view and copy a number of records held by the State Compensation Insurance Authority (SCIA) under the Colorado Open Records Act (CORA).
- SCIA rejected the request arguing that it was not included in Colorado's definition of a public body and therefor not subject to open records requests.
- Dawson filed a lawsuit seeking to compel the agency to provide the documents and the trial court ruled in favor Dawson declaring that the SCIA was in fact subject to public records requests.[1]
- SCIA appealed the decision.
Ruling of the court
The trial court ruled in favor of Dawson and ordered the documents disclosed.
The Court of Appeals affirmed the ruling of the trial court and confirmed that SCIA was a public body and subject to CORA.
The court ruled that the SCIA was a "statutorily-created political subdivision" no different from any other subdivision, subject to CORA despite the fact that CORA's definition of subdivision does not create SCIA. Based on this, they concluded that SCIA was in fact a public body subject to public records requests.[1]
