Hackworth v. Board of Education

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Hackworth vs. Board of Education Number: 214 Ga. App. 17, 447 S.E.2d 78 Year: 1994 State: Georgia Court: Georgia Court of Appeals Other lawsuits in Georgia Other lawsuits in 1994 Precedents include: This case established a number of important precedents: 1.) This case affirmed the ruling of Red & Black Publishing Company v. Board of Regents in determining that an organization that acts as the vehicle for a public body to accomplish a government function is in fact considered a public agency. 2.) Personal files are not automatically exempt but exempt material may be redacted from them.

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Hackworth v. Board of Education was a 1994 case before the Georgia Court of Appeals concerning the applicability of the open records law to private corporations.

Important precedents

This case established a number of important precedents:
1.) This case affirmed the ruling of Red & Black Publishing Company v. Board of Regents in determining that an organization that acts as the vehicle for a public body to accomplish a government function is in fact considered a public agency.
2.) Personal files are not automatically exempt but exempt material may be redacted from them.

Background

• The Atlanta school board contracts with Laidlaw transportation for the maintenance and driving of the school buses owned by the school board.
• CB Hackworth, an Atlanta television producer, submitted a records requests to the school board requesting records of certain named bus drivers.
• The school board granted Hackworth the documents they were in possession of but claimed that the other documents were in the possession of Laidlaw.
• Laidlaw refused to surrender the documents claiming that they were not a public body and thus not subject to the act. They also claimed that the records contained personal information that would result in an unwarranted invasion of privacy.
• The trial court ruled in favor of Laidlaw transportation.

Ruling of the court

The trial court ruled in favor of the Board of Education and Laidlaw but did not disclose the rationale for its decision.

The Supreme Court overturned the decision of the trial court. The court first determined that transporting students to and from school was a clear governmental function delegated to the school board and that Laidlaw transportation was the vehicle which the school board used to accomplish that task. The court then went on to determine that the records in question were not exempt just because they were "similar to medical records." Instead the court opted to remand the remainder of the decision to the trial court to determine what, if any, information was exempt under privacy exemptions. The court did however feel that the majority of the information relating to the actual task of transporting the students to and from school was in the public interest and should thus be made available.

Associated cases

• Red & Black Publishing Company v. Board of Regents

External links

• Ruling of the Court