Sheridan Newspapers v. City of Sheridan
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Sheridan Newspapers v. City of Sheridan was a case before the Wyoming Supreme Court in 1983 concerning police records.
Important precedents
This case:
- Eliminated the possibility of exempt categories of records
- Required a case by case consideration of exempt records with the burden of proof resting upon the records custodian for any denied records request.
Background
- The Sheridan Police Department has historically rejected records requests for investigations, the "rolling log" (a document recording everything reported to dispatchers and contains no material from investigation) and "case reports" (the full reports of any police activity and may contain investigation materials) and instead has provided press releases prepared specifically for the news agencies.[1]
- The local news agencies sued for the actual records of the "case reports" and "rolling logs" based on the arguments that:
- 1.)the police chief must consider the denials on a case by case basis and not exempt entire categories and
- 2.)that the police chief must provide a written statement, stating the grounds for the denial pursuant to Wyoming law 9-9-103(e).[1]
Criticisms of the FOIA request
The police department, in addition to the newspapers, appealed the ruling of the trial court, despite the court ruling in their favor, claiming that, the trial court changed Wyoming law by requiring a case by case review of denied materials and by restricting the police chiefs power to withhold documents. The trial court required the release of a certain number of case reports including "'jail log,' 'reports of the investigation of vehicular and traffic accidents' and 'complaints and citations issued'," and only allowed for their exemption on a case by case basis.[1]
Ruling of the court
Concerning the appeal of the Newspapers
The court began by quoting Williams v. Stafford which established that court records should be open as much as possible in order "to enhance the public trust and confidence in the judicial process."[1] They went on to cite Record-Times, Inc. v. Town of Wheatland was an important precedent establishing that the intention of the open records act is to make visible the business of the government in order to encourage those in public positions to act responsibly and "carefully weigh their decisions."[1] Based on these two rulings and the intention of the legislature in enacting the public records act, the court ruled in favor of the Newspapers. This ruling eliminated the potential for exempted categories of records, instead mandated a case by case review of the records. It required explicit statutory defense for any records denials, thus placing the burden of proof on the records custodian for prooving that the records truly are exempt. In addition, the court made clear that exempt portions of records must be removed and non-exempt records be released. Thus, the ruling of the district court was reversed and the policy of the police department had to be changed.
Concerning the appeal of the police department
The court affirmed the ruling of the trial court as it was in line with their ruling with regard to the appeal of the newspapers.
