Board of Trustees of Woodstock Academy v. FOIC was a 1980 case before the Connecticut Supreme Court concerning the application of open records laws to private corporations.
Important precedents
This case incorporated into the Connecticut Freedom of Information Act the Federal criteria for private companies subject to public records requests, including:
"(1) whether the entity performs a governmental function;
(2) the level of government funding;
(3) the extent of government involvement or regulation; and
(4) whether the entity was created by the government."[1]
Background
- Woodstock, was established by the Connecticut Legislature in 1802. It was designed to provide secondary schooling to the town of Woodstock, because Woodstock did not currently have a high school. The Woodstock town Board of Education annually declares that the Academy is the designated location to provide secondary educational services for the town.
- Almost all the children from the town of Woodstock attend the academy and the city pays the students' tuition from funds collected from taxes. This amounts to 95.32% of its funding from various cities and 75% from the town of Woodstock itself.
- Ernest St. Jean, Vernon Fuerst and Robert Peabody submitted an open records request to the Board of Trustees of Woodstock Academy for all the present and past financial records.
- Woodstock Academy denied the request claiming that it was not a public body and thus not subject to the act.
- The Connecticut Freedom of Information Commission ruled in favor of Fuerst and Peabody, declaring that the Academy was in fact a public body and the records in question were not exempt.
- The trial court affirmed the decision of the commission.
- Woodstock Academy appealed the decision claiming that the court erred in declaring that it was a public body.[1]
Ruling of the court
Both the Connecticut Freedom of Information Commission and the trial court ruled in favor of Fuerst and Peabody, declaring that the Academy is a public body subject to records requests.
The Supreme Court
Citing Wilson v. Freedom of Information Commission the Court turned to the Federal FOIA to help aid in deciding a question which is ambiguous within Connecticut legal history. The court turned to the Federal Courts "functional equivalence test", which includes the following factors:
"(1) whether the entity performs a governmental function;
(2) the level of government funding;
(3) the extent of government involvement or regulation; and
(4) whether the entity was created by the government."[1]
The Court went on to find that the Academy met all four criteria as it performed the function of providing education, was entirely government funded, was regulated by the state board of education and was created by statute. The court thus affirmed the decision of the trial court and ordered the release of the documents in question.[1]
Associated cases
See Also
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