Wyoming Department of Transportation v. International Union of Operating Engineers Local Union 800

From Sunshine Review

Wyoming Department of Transportation vs. International Union of Operating Engineers Local Union 800 Number: 1995 WY 211, 908 P.2d 970 Year: 1995 State: Wyoming Court: {{{Court}}} Other lawsuits in Wyoming Other lawsuits in 1995 Precedents include: This case established that names and address did not automatically qualify as exempt personal records.

Contents 1 Important precedents 2 Background 3 Supporters of the FOIA request 4 Criticisms of the FOIA request 5 Ruling of the court 6 Associated cases 7 See Also 8 External links 9 References

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Wyoming Department of Transportation v. International Union of Operating Engineers Local Union 800 was a case before the Wyoming Supreme Court in 1995 concerning payroll records.

[edit] Important precedents

This case established that names and address did not automatically qualify as exempt personal records.

[edit] Background

• The Wyoming Transportation Department (WTD) requires wage statements for all wrokers excluding the names and address for all privately contracted highway construction projects. The federal government requires similar information for any projects receiving federal funding. However, the federal forms include the names and addresses of employees which are expunged before the record is stored with the Federal Highway Administration (FHA). The goal of these wage reports is to insure that private contractors are complying with wage law.
• The union made an open records request for both the federal and state forms.
• The state provided both forms. It however, removed the names and addresses from the federal forms before releasing it.
• The union filed suit for the names and addresses. ^[1]

[edit] Supporters of the FOIA request

[edit] Criticisms of the FOIA request

[edit] Ruling of the court

The district court ruled in favor of the union, requiring the release of the federal forms in their entirety.

The Supreme Court affirmed the decision of the district court. The supreme court declared that the names and addresses in question did not constitute trade secrets or sociological data, and could not find a federal statute that prohibited the release of the information. Further, the release of the information would not constitute an invasion of privacy, as the employees had already forfeited their information to the employer in full knowledge that it would be given to the state. Finally, the public benefit of insuring the full cooperation of private corporations with regard to wage law presents a public benefit that far outweighs any invasion of privacy that may occur. All of these factors led to the decision of the court to uphold the district court's ruling. ^[1]

[edit] Associated cases

[edit] See Also

• Wyoming Sunshine Law

[edit] External links

• Ruling of the Court

[edit] References

1. ↑ ^{1.0 1.1} Ruling fo the Court