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Request By:
TMr, David L. Drake
Attorney at Law
107 Park Place
Covington, Ky 41011Mr. Ted Knoebber
City Attorney
319 York Street
Newport, Ky 41071George Johnson, Mayor
c/o City of Ryland Heights
Route , Box 312C
Ryland Heights, Ky 41015

Opinion

Opinion By: Chris Gorman, Attorney General; Amye B, Majors, Assistant Attorney General

OPEN RECORDS DECISION

This matter comes to the Atorney General on appeal from the Ryland Heights city Council's denial of Mr. David L. Drake's request for access to the tape recordings of the Council's meetings. Mr. Ted knoebber, attorney for the City of Ryland Heights, denied Mr. Drake's request. Relying on KRS 61.878(1) (g), he granted that the tapes are exempt from public inspection since they are preliminary in character.

The question presented in this appeal is whether the city properly invoked KRS 61.878(1)(g) to authorize nondisclosure of the request records. We believe that OAG 92-111, a copy of which is attached, is dispositive of this appeal. FN 1 In that opinion, we held that if an attorney elects to make a tape recording of its public meetings, and that is owned, used or in its possession, it may not properly be treated as a preliminary document, but should be made available to the public upon request. (FN)

We have been advised by Mayor George Johnson that the tapes used by the city clerk to assst her in preparing the official minutes of Council metings are purchased by the clerk at her own expense. Assuming this to be the case, we conclude that the tapes do not have to be made available for inspection. As we noted at p. 4 of OAG 92-111:

[We do not] mean to suggest that a secretary or clerk who personally purchases a tape and records the meeting on his or hwer own initiative to assist in the preparation of the minutes, must release the tape for public inspection. Under these circumstances, the tape could not be treated as a public record, but would instead be considered the clerk's personal property. (Citation omitted.) Our holding is limited to those instances when the agency directs that a tape be made of its public meeting, for wqhatever purpose, and that tape is purchased with agency funds.

Only if the city expends its own funds in the purchase of the tapes, and directs the clerk to record its meetinga. are those tapes subject to public inspection. We therefore conclude that the Ryland Heights city Coucil properly denied Mr. Drake's request.

Mr. Drake may challenge this decision by initiating action in the appropriate circuit court pursuant to KRS 61.880(5) and KRS 61.882.

Footnotes

Footnotes

1 Please note that the term "public record" was redefined by the 1992 General Assembly. The current definition, which became effective on July 14, 1992, is found at KRS 61.870(2).

LLM Summary
The decision concludes that the Ryland Heights City Council properly denied Mr. Drake's request for access to the tape recordings of the Council's meetings. The denial was based on the fact that the tapes were purchased by the city clerk at her own expense and used to assist in preparing the official minutes, thus making them her personal property and not public records. This conclusion follows the precedent set in OAG 92-111, which distinguishes between tapes made and purchased under the direction of the agency and those made for personal assistance by an individual.
Disclaimer:
The Sunshine Law Library is not exhaustive and may contain errors from source documents or the import process. Nothing on this website should be taken as legal advice. It is always best to consult with primary sources and appropriate counsel before taking any action.
Type:
Open Records Decision
Lexis Citation:
1992 Ky. AG LEXIS 205
Cites:
Forward Citations:
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