Wyoming Department of Transportation v. International Union of Operating Engineers Local Union 800
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Wyoming Department of Transportation v. International Union of Operating Engineers Local Union 800 was a case before the Wyoming Supreme Court in 1995 concerning payroll records.
Important precedents
This case established that names and address did not automatically qualify as exempt personal records.
Background
- The Wyoming Transportation Department (WTD) requires wage statements for all workers excluding the names and address for all privately contracted highway construction projects. The federal government requires similar information for any projects receiving federal funding. However, the federal forms include the names and addresses of employees which are expunged before the record is stored with the Federal Highway Administration (FHA). The goal of these wage reports is to insure that private contractors are complying with wage law.
- The union made an open records request for both the federal and state forms.
- The state provided both forms. It however, removed the names and addresses from the federal forms before releasing it.
- The union filed suit for the names and addresses.[1]
Supporters of the FOIA request
Criticisms of the FOIA request
Ruling of the court
The district court ruled in favor of the union, requiring the release of the federal forms in their entirety.
The Supreme Court affirmed the decision of the district court. The supreme court declared that the names and addresses in question did not constitute trade secrets or sociological data, and could not find a federal statute that prohibited the release of the information. Further, the release of the information would not constitute an invasion of privacy, as the employees had already forfeited their information to the employer in full knowledge that it would be given to the state. Finally, the public benefit of insuring the full cooperation of private corporations with regard to wage law presents a public benefit that far outweighs any invasion of privacy that may occur. All of these factors led to the decision of the court to uphold the district court's ruling.[1]
