Pottle v. School Committee of Braintree
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Pottle v. School Committee of Braintree was a case before the Massachusetts Supreme Judicial Court in 1985 concerning the release of names and home address as public records.
Important precedents
This case affirmed that the home addresses of public employees are not exempt under the Massachusetts Public Records Act.
Background
- The Massachusetts Federation of Teachers, AFT, AFL-CIO (MFT) submitted an open records requests for the names, job descriptions, and home adressess of all employees within the Braintree public schools.
- Teachers within the Braintree district, including Pottle, as well as the local teacher's union filed suit, seeking to compel the school superintendent to withhold the records as exempt under the Massachusetts Public Records Act under Section 7, Twenty-sixth (c) which exempts personal files, the release of which would "constitute an unwarranted invasion of personal privacy"[1].
- The trial court delivered a split decision.
- The decision was appealed.
Ruling of the court
The trial court delivered a split decision. It determined that the names and job descriptions were public record pertaining to the business of the school board. However, it held that the act did not apply to the teacher's home addresses.
The Supreme Court agreed overturned part of the trial courts decision and ordered the names and job descriptions as well as the home addresses released under the public records act.
The Supreme Court cited Hastings & Sons Publishing Co. v. City Treasurer of Lynn, which held that home addresses were not the type of private information that the legislature intended to protect with that exemption because the information did not constitute a true invasion of privacy as the information was available elsewhere. Based on this ruling the court ruled in favor of the MFT and the school committee and ordered the records request filled in its entirety.
Associated cases
- Hastings & Sons Publishing Co. v. City Treasurer of Lynn
- Globe Newspaper Co. v. Boston Retirement Board
