Hastings & Sons Publishing Co. v. City Treasurer of Lynn
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Hastings & Sons Publishing Co. v. City Treasurer of Lynn was a case before the Massachusetts Supreme Judicial Court in 1978 concerning police payroll records which contained home addresses.
Important precedents
This case established a few important precedents:
1.) That salary cards are subject to public records requests.
2.) That home addresses of city employees do not qualify for privacy protection exemptions.
Background
- On January 6, 1976, Hastings & Sons Publishing Co. submitted a public records request to the city treasurer for the records of the base pay and overtime pay for all city employees in 1975.
- The treasurer acknowledged the legitimacy of the request but denied it based on an injuction the police department had obtained to prevent the release of these records.
- The police department became party to the lawsuit and argued in favor of exemption based upon privacy rights.
- The court ruled in favor of the newspapers, ordering the documents disclosed.
- The police department appealed the decision.
Ruling of the court
The trial court ruled in favor of the police department, ordering the release of the documents in question.
The Supreme Court affirmed the ruling of the trial court.
The court ruled that the documents in question were certainly public records under the Massachusetts Public Records Act. They further determined that the police had no claim to privacy, deciding that the intention of the legislature with regard to the privacy exemption was to protect facts of an intensely personal nature. Further, the court ruled that any claim to privacy was outweighed by the public's interest in the flow of public money. Thus the court ordered the documents released.
