PaFOIC

Granted: Central York superintendent's W-2s, despite PSEA objections

Granted: A request for W-2 forms for the Central York School District superintendent, as well as a copy of minutes of a board meeting at which the superintendent's paid/reimbursed leave of absence was discussed.
From the Pennsylvania Freedom of Information Coalition

Granted: A request for W-2 forms for the Central York School District superintendent, as well as a copy of minutes of a board meeting at which the superintendent's paid/reimbursed leave of absence was discussed.

The district provided a number of other records related to the superintendent, but did not provide these records. The requester considered this a "deemed denial" of his request for those records, and appealed to the Office of Open Records.

Following the appeal to the Office of Open Records, the district indicated that it intended to release the requested records.

The Pennsylvania School Education Association subsequently requested permission to submit information to the OOR on behalf of the superintendent. The PSEA argued that the W-2 forms were not specifically identified in the request, and therefore the district had no obligation to provide them. It also claimed that the W-2s are confidential personal tax documents, althought he OOR noted it provided no legal support for that statement.

The PSEA also said that while it was aware of the OOR's determinations granting the release of W-2 tax forms, it was unaware of any court decision affirming the OOR's decisions. The OOR noted that PSEA provided no further legal support for its position from the Right to Know Law, or applicable federal or state case law.

In its ruling, the OOR noted that the district offered no argument in support of withholding the records, and had stated that it intended to release the records at issue to the requester. It also noted that it has previously issued many determinations that W-2 tax forms are public record and subject to release:
The OOR noted that the PSEA also raised concerns about due process regarding the superintendent's rights to object to the release of his W-2s. "The district did not raise any such issue in the appeal process," the OOR said. "In this case, the OOR granted PSEA's request to submit information on behalf of [the superintendent}, thus dispelling any due process concerns."

Campbell vs. Central York School District -- AP 2009-0432