Lamson v. Montgomery County, Md.

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At issue was whether Petitioner’s request for the release of notes containing possible personnel information relating to her performance as an employee of the Montgomery County Attorney’s office were subject to disclosure under the Maryland Public Information Act (MPIA).Montgomery County (Respondent) withheld the subject notes when responding to Petitioner’s MPIA request, claiming that the notes were privileged, non-public information. Petitioner then filed a complaint in the circuit court alleging that Respondent violated the MPIA and requesting an order requiring the disclosure of the documents. The circuit court granted Respondent’s motion to dismiss, concluding that an in camera review was not required because the notes were not considered personnel records pursuant to the Montgomery County personnel regulations. The Court of Special Appeals affirmed. The Court of Appeals vacated the judgment of the Court of Special Appeals and remanded the case to the circuit court for further proceedings, holding (1) the trial court reviewing the denial of an MPIA request must be satisfied that the rationale offered by the agency supports the denial of the request; and (2) the trial court in this case did not sufficiently review the denial of Petitioner’s MPIA request. View "Lamson v. Montgomery County, Md." on Justia Law