Sublette County Rural Health Care District v. Miley

From Sunshine Review

Sublette County Rural Health Care District vs. Miley Number: 1997 WY 94, 942 P.2d 1101 Year: 1997 State: Wyoming Court: {{{Court}}} Other lawsuits in Wyoming Other lawsuits in 1997 Precedents include: Establish criteria for determining whether trade secrets are exempt based on the affect on the ability to gather information in the future and the potential affect on competition.

Contents 1 Important precedents 2 Background 3 Ruling of the court 4 Associated cases 5 See Also 6 External links 7 References

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Sublette County Rural Health Care District v. Miley was a case before the Wyoming Supreme Court in 1997 concerning the open records exemption for trade secrets (Statute 16-4-203(d)(v)).

[edit] Important precedents

This case established the use of two criteria for determining whether trade secrets are exempt:
1.) the affect on the future ability of government to obtain information and
2.) potential harm caused on the competitive position of individuals who provide information

[edit] Background

• The district owns a number of medical buildings which they rent to doctors for free. They pay these doctors a stipend for running the clinics and the doctors charge fees for patient services. The income from the fees and the stipend is entirely the doctors property and is used to maintain the clinic and as income by the doctors.
• On January 24, 1996, Miley made a records request of the financial reports of the doctors who maintain these clinics.
• The district rejected the request claiming that the records of the doctors were records of private business practices that qualified as trade secrets and if disclosed would place the doctors at a competitive disadvantage.
• Miley filed suit and on May 20, 1996 the district court ruled in favor of Miley and ordered the release of the records.

[edit] Ruling of the court

The court ruled in favor of the hospital, overturning the district ruling. They overturned the ruling on the grounds of the statute alone. The court determined that the intent of the statute was to encourage providing financial information to a government agency and to protect the rights of groups that are required to provide financial information. Federal FOIA law established a two factor test based on these intentions, to determine if material does in fact constitute trade secrets. This test questions:
1.) the affect on the future ability of government to obtain information and
2.) potential harm caused on the competitive position of individuals who provide information Based on these test questions, the court ruled in favor of the district allowing the financial statments to remain exempt and sealed.

[edit] Associated cases

[edit] See Also

• Wyoming Sunshine Law

[edit] External links

• Ruling of the Court

[edit] References