Connecticut 2023 Regular Session

Connecticut Senate Bill SB01221 Compare Versions

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	7	+	General Assembly Substitute Bill No. 1221
	8	+	January Session, 2023
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4		-	Substitute Senate Bill No. 1221
5		-
6		-	Public Act No. 23-200
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9	14		AN ACT CONCERNING THE ENFORCEMENT OF VIOLATIONS OF
10	15		THE FREEDOM OF INFORMATION ACT.
11	16		Be it enacted by the Senate and House of Representatives in General
12	17		Assembly convened:
13	18
14		-	Section 1. Subsection (b) of section 1-206 of the general statutes is
15		-	repealed and the following is substituted in lieu thereof (Effective October
16		-	1, 2023):
17		-	(b) (1) Any person denied the right to inspect or copy records under
18		-	section 1-210 or wrongfully denied the right to attend any meeting of a
19		-	public agency or denied any other right conferred by the Freedom of
20		-	Information Act may appeal therefrom to the Freedom of Information
21		-	Commission, by filing a notice of appeal with said commission. A notice
22		-	of appeal shall be filed not later than thirty days after such denial, except
23		-	in the case of an unnoticed or secret meeting, in which case the appeal
24		-	shall be filed not later than thirty days after the person filing the appeal
25		-	receives actual or constructive notice that such meeting was held. For
26		-	purposes of this subsection, such notice of appeal shall be deemed to be
27		-	filed on the date it is received by said commission or on the date it is
28		-	postmarked, if received more than thirty days after the date of the denial
29		-	from which such appeal is taken. Upon receipt of such notice, the
30		-	commission shall serve upon all parties, by certified or registered mail
31		-	or by electronic transmission, a copy of such notice together with any Substitute ~~Senate~~ Bill No. 1221
	19	+	Section 1. Subsection (b) of section 1-206 of the general statutes is 1
	20	+	repealed and the following is substituted in lieu thereof (Effective October 2
	21	+	1, 2023): 3
	22	+	(b) (1) Any person denied the right to inspect or copy records under 4
	23	+	section 1-210 or wrongfully denied the right to attend any meeting of a 5
	24	+	public agency or denied any other right conferred by the Freedom of 6
	25	+	Information Act may appeal therefrom to the Freedom of Information 7
	26	+	Commission, by filing a notice of appeal with said commission. A notice 8
	27	+	of appeal shall be filed not later than thirty days after such denial, except 9
	28	+	in the case of an unnoticed or secret meeting, in which case the appeal 10
	29	+	shall be filed not later than thirty days after the person filing the appeal 11
	30	+	receives actual or constructive notice that such meeting was held. For 12
	31	+	purposes of this subsection, such notice of appeal shall be deemed to be 13
	32	+	filed on the date it is received by said commission or on the date it is 14
	33	+	postmarked, if received more than thirty days after the date of the denial 15
	34	+	from which such appeal is taken. Upon receipt of such notice, the 16
	35	+	commission shall serve upon all parties, by certified or registered mail 17
	36	+	or by electronic transmission, a copy of such notice together with any 18 Substitute Bill No. 1221
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33		-	Public Act No. 23-200 2 of 7
34	38
35		-	other notice or order of such commission. In the case of the denial of a
36		-	request to inspect or copy records contained in a public employee's
37		-	personnel or medical file or similar file under subsection (c) of section 1-
38		-	214, the commission shall include with its notice or order an order
39		-	requiring the public agency to notify any employee whose records are
40		-	the subject of an appeal, and the employee's collective bargaining
41		-	representative, if any, of the commission's proceedings and, if any such
42		-	employee or collective bargaining representative has filed an objection
43		-	under said subsection (c), the agency shall provide the required notice
44		-	to such employee and collective bargaining representative by certified
45		-	mail, return receipt requested, by electronic transmission or by hand
46		-	delivery with a signed receipt. A public employee whose personnel or
47		-	medical file or similar file is the subject of an appeal under this
48		-	subsection may intervene as a party in the proceedings on the matter
49		-	before the commission. Said commission shall, after due notice to the
50		-	parties, hear and decide the appeal [within] not later than one year after
51		-	the filing of the notice of appeal. The commission shall adopt regulations
52		-	in accordance with chapter 54, establishing criteria for those appeals
53		-	which shall be privileged in their assignment for hearing. Any such
54		-	appeal shall be heard not later than thirty days after receipt of a notice
55		-	of appeal and decided not later than sixty days after the hearing. If a
56		-	notice of appeal concerns an announced agency decision to meet in
57		-	executive session or an ongoing agency practice of meeting in executive
58		-	sessions, for a stated purpose, the commission or a member or members
59		-	of the commission designated by its chairperson shall serve notice upon
60		-	the parties in accordance with this section and hold a preliminary
61		-	hearing on the appeal not later than seventy-two hours after receipt of
62		-	the notice, provided such notice shall be given to the parties at least
63		-	forty-eight hours prior to such hearing. During such preliminary
64		-	hearing, the commission shall take evidence and receive testimony from
65		-	the parties. If after the preliminary hearing the commission finds
66		-	probable cause to believe that the agency decision or practice is in
67		-	violation of sections 1-200 and 1-225, the agency shall not meet in Substitute Senate Bill No. 1221
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	43	+	other notice or order of such commission. In the case of the denial of a 19
	44	+	request to inspect or copy records contained in a public employee's 20
	45	+	personnel or medical file or similar file under subsection (c) of section 1-21
	46	+	214, the commission shall include with its notice or order an order 22
	47	+	requiring the public agency to notify any employee whose records are 23
	48	+	the subject of an appeal, and the employee's collective bargaining 24
	49	+	representative, if any, of the commission's proceedings and, if any such 25
	50	+	employee or collective bargaining representative has filed an objection 26
	51	+	under said subsection (c), the agency shall provide the required notice 27
	52	+	to such employee and collective bargaining representative by certified 28
	53	+	mail, return receipt requested, by electronic transmission or by hand 29
	54	+	delivery with a signed receipt. A public employee whose personnel or 30
	55	+	medical file or similar file is the subject of an appeal under this 31
	56	+	subsection may intervene as a party in the proceedings on the matter 32
	57	+	before the commission. Said commission shall, after due notice to the 33
	58	+	parties, hear and decide the appeal [within] not later than one year after 34
	59	+	the filing of the notice of appeal. The commission shall adopt regulations 35
	60	+	in accordance with chapter 54, establishing criteria for those appeals 36
	61	+	which shall be privileged in their assignment for hearing. Any such 37
	62	+	appeal shall be heard not later than thirty days after receipt of a notice 38
	63	+	of appeal and decided not later than sixty days after the hearing. If a 39
	64	+	notice of appeal concerns an announced agency decision to meet in 40
	65	+	executive session or an ongoing agency practice of meeting in executive 41
	66	+	sessions, for a stated purpose, the commission or a member or members 42
	67	+	of the commission designated by its chairperson shall serve notice upon 43
	68	+	the parties in accordance with this section and hold a preliminary 44
	69	+	hearing on the appeal not later than seventy-two hours after receipt of 45
	70	+	the notice, provided such notice shall be given to the parties at least 46
	71	+	forty-eight hours prior to such hearing. During such preliminary 47
	72	+	hearing, the commission shall take evidence and receive testimony from 48
	73	+	the parties. If after the preliminary hearing the commission finds 49
	74	+	probable cause to believe that the agency decision or practice is in 50
	75	+	violation of sections 1-200 and 1-225, the agency shall not meet in 51
	76	+	executive session for such purpose until the commission decides the 52
	77	+	appeal. If probable cause is found by the commission, it shall conduct a 53 Substitute Bill No. 1221
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71		-	executive session for such purpose until the commission decides the
72		-	appeal. If probable cause is found by the commission, it shall conduct a
73		-	final hearing on the appeal and render its decision not later than five
74		-	days after the completion of the preliminary hearing. Such decision shall
75		-	specify the commission's findings of fact and conclusions of law.
76		-	(2) In any appeal to the Freedom of Information Commission under
77		-	subdivision (1) of this subsection or subsection (c) of this section, the
78		-	commission may confirm the action of the agency or order the agency
79		-	to provide relief that the commission, in its discretion, believes
80		-	appropriate to rectify the denial of any right conferred by the Freedom
81		-	of Information Act. The commission may declare null and void any
82		-	action taken at any meeting which a person was denied the right to
83		-	attend and may require the production or copying of any public record.
84		-	In addition, upon the finding that a denial of any right created by the
85		-	Freedom of Information Act was without reasonable grounds and after
86		-	the custodian or other official directly responsible for the denial has
87		-	been given an opportunity to be heard at a hearing conducted in
88		-	accordance with sections 4-176e to 4-184, inclusive, the commission
89		-	may, in its discretion, impose against the custodian or other official a
90		-	civil penalty of not less than twenty dollars nor more than [one] five
91		-	thousand dollars. If the commission finds that a person has taken an
92		-	appeal under this subsection frivolously, without reasonable grounds
93		-	and solely for the purpose of harassing the agency from which the
94		-	appeal has been taken, after such person has been given an opportunity
95		-	to be heard at a hearing conducted in accordance with sections 4-176e to
96		-	4-184, inclusive, the commission may, in its discretion, impose against
97		-	that person a civil penalty of not less than twenty dollars nor more than
98		-	one thousand dollars. The commission shall notify a person of a penalty
99		-	levied against [him] such person pursuant to this subsection by written
100		-	notice sent by certified or registered mail or electronic transmission. If a
101		-	person fails to pay the penalty [within] not later than thirty days [of]
102		-	after receiving such notice, the Superior Court shall, on application of Substitute Senate Bill No. 1221
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106		-	the commission, issue an order requiring the person to pay the penalty
107		-	imposed. If the executive director of the commission has reason to
108		-	believe an appeal under subdivision (1) of this subsection or subsection
109		-	(c) of this section (A) presents a claim beyond the commission's
110		-	jurisdiction; (B) would perpetrate an injustice; or (C) would constitute
111		-	an abuse of the commission's administrative process, the executive
112		-	director shall not schedule the appeal for hearing without first seeking
113		-	and obtaining leave of the commission. The commission shall provide
114		-	due notice to the parties and review affidavits and written argument
115		-	that the parties may submit and grant or deny such leave summarily at
116		-	its next regular meeting. The commission shall grant such leave unless
117		-	it finds that the appeal: (i) Does not present a claim within the
118		-	commission's jurisdiction; (ii) would perpetrate an injustice; or (iii)
119		-	would constitute an abuse of the commission's administrative process.
120		-	Any party aggrieved by the commission's denial of such leave may
121		-	apply to the superior court for the judicial district of New Britain,
122		-	[within] not later than fifteen days of the commission meeting at which
123		-	such leave was denied, for an order requiring the commission to hear
124		-	such appeal.
125		-	(3) In making the findings and determination under subdivision (2)
126		-	of this subsection the commission shall consider the nature of any
127		-	injustice or abuse of administrative process, including, but not limited
128		-	to: (A) The nature, content, language or subject matter of the request or
129		-	the appeal, including, among other factors, whether the request or
130		-	appeal is repetitious or cumulative; (B) the nature, content, language or
131		-	subject matter of prior or contemporaneous requests or appeals by the
132		-	person making the request or taking the appeal; (C) the nature, content,
133		-	language or subject matter of other verbal and written communications
134		-	to any agency or any official of any agency from the person making the
135		-	request or taking the appeal; (D) any history of nonappearance at
136		-	commission proceedings or disruption of the commission's
137		-	administrative process, including, but not limited to, delaying Substitute Senate Bill No. 1221
	84	+	final hearing on the appeal and render its decision not later than five 54
	85	+	days after the completion of the preliminary hearing. Such decision shall 55
	86	+	specify the commission's findings of fact and conclusions of law. 56
	87	+	(2) In any appeal to the Freedom of Information Commission under 57
	88	+	subdivision (1) of this subsection or subsection (c) of this section, the 58
	89	+	commission may confirm the action of the agency or order the agency 59
	90	+	to provide relief that the commission, in its discretion, believes 60
	91	+	appropriate to rectify the denial of any right conferred by the Freedom 61
	92	+	of Information Act. The commission may declare null and void any 62
	93	+	action taken at any meeting which a person was denied the right to 63
	94	+	attend and may require the production or copying of any public record. 64
	95	+	In addition, upon the finding that a denial of any right created by the 65
	96	+	Freedom of Information Act was without reasonable grounds and after 66
	97	+	the custodian or other official directly responsible for the denial has 67
	98	+	been given an opportunity to be heard at a hearing conducted in 68
	99	+	accordance with sections 4-176e to 4-184, inclusive, the commission 69
	100	+	may, in its discretion, impose against the custodian or other official a 70
	101	+	civil penalty of not less than twenty dollars nor more than [one] ten 71
	102	+	thousand dollars. If the commission finds that a person has taken an 72
	103	+	appeal under this subsection frivolously, without reasonable grounds 73
	104	+	and solely for the purpose of harassing the agency from which the 74
	105	+	appeal has been taken, after such person has been given an opportunity 75
	106	+	to be heard at a hearing conducted in accordance with sections 4-176e to 76
	107	+	4-184, inclusive, the commission may, in its discretion, impose against 77
	108	+	that person a civil penalty of not less than twenty dollars nor more than 78
	109	+	one thousand dollars. The commission shall notify a person of a penalty 79
	110	+	levied against [him] such person pursuant to this subsection by written 80
	111	+	notice sent by certified or registered mail or electronic transmission. If a 81
	112	+	person fails to pay the penalty [within] not later than thirty days [of] 82
	113	+	after receiving such notice, the Superior Court shall, on application of 83
	114	+	the commission, issue an order requiring the person to pay the penalty 84
	115	+	imposed. If the executive director of the commission has reason to 85
	116	+	believe an appeal under subdivision (1) of this subsection or subsection 86
	117	+	(c) of this section (A) presents a claim beyond the commission's 87 Substitute Bill No. 1221
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141		-	commission proceedings; and (E) the refusal to participate in settlement
142		-	conferences conducted by a commission ombudsman in accordance
143		-	with the commission's regulations.
144		-	(4) Notwithstanding any provision of this subsection, [to the
145		-	contrary,] in the case of an appeal to the commission of a denial by a
146		-	public agency, the commission may, upon motion of such agency,
147		-	confirm the action of the agency and dismiss the appeal without a
148		-	hearing if it finds, after examining the notice of appeal and construing
149		-	all allegations most favorably to the appellant, that (A) the agency has
150		-	not violated the Freedom of Information Act, or (B) the agency has
151		-	committed a technical violation of the Freedom of Information Act that
152		-	constitutes a harmless error that does not infringe the appellant's rights
153		-	under said act.
154		-	(5) Notwithstanding any provision of this subsection, in the case of
155		-	an appeal to the commission of a denial by a public agency where, after
156		-	a hearing, the commission finds the public agency is engaging in a
157		-	practice or pattern of conduct that constitutes an obstruction of any right
158		-	conferred by the Freedom of Information Act or reckless, wilful or
159		-	wanton misconduct with regard to the delay or denial of responses to
160		-	requests for public records under said act, the commission may impose
161		-	a civil penalty of not less than twenty dollars nor more than five
162		-	thousand dollars against a custodian or other official of such public
163		-	agency, and order such other relief that the commission, in its discretion,
164		-	determines is appropriate to rectify such obstruction or misconduct and
165		-	to deter such public agency from violating the Freedom of Information
166		-	Act. In case of any failure or refusal to comply with any order issued
167		-	under this subdivision, the commission may apply to the superior court
168		-	for the judicial district of New Britain for an order requiring such public
169		-	agency to comply with such order.
170		-	[(5)] (6) Notwithstanding any provision of this subsection, a public
171		-	agency may petition the commission for relief from a requester that the Substitute Senate Bill No. 1221
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	124	+	jurisdiction; (B) would perpetrate an injustice; or (C) would constitute 88
	125	+	an abuse of the commission's administrative process, the executive 89
	126	+	director shall not schedule the appeal for hearing without first seeking 90
	127	+	and obtaining leave of the commission. The commission shall provide 91
	128	+	due notice to the parties and review affidavits and written argument 92
	129	+	that the parties may submit and grant or deny such leave summarily at 93
	130	+	its next regular meeting. The commission shall grant such leave unless 94
	131	+	it finds that the appeal: (i) Does not present a claim within the 95
	132	+	commission's jurisdiction; (ii) would perpetrate an injustice; or (iii) 96
	133	+	would constitute an abuse of the commission's administrative process. 97
	134	+	Any party aggrieved by the commission's denial of such leave may 98
	135	+	apply to the superior court for the judicial district of New Britain, 99
	136	+	[within] not later than fifteen days of the commission meeting at which 100
	137	+	such leave was denied, for an order requiring the commission to hear 101
	138	+	such appeal. 102
	139	+	(3) In making the findings and determination under subdivision (2) 103
	140	+	of this subsection the commission shall consider the nature of any 104
	141	+	injustice or abuse of administrative process, including, but not limited 105
	142	+	to: (A) The nature, content, language or subject matter of the request or 106
	143	+	the appeal, including, among other factors, whether the request or 107
	144	+	appeal is repetitious or cumulative; (B) the nature, content, language or 108
	145	+	subject matter of prior or contemporaneous requests or appeals by the 109
	146	+	person making the request or taking the appeal; (C) the nature, content, 110
	147	+	language or subject matter of other verbal and written communications 111
	148	+	to any agency or any official of any agency from the person making the 112
	149	+	request or taking the appeal; (D) any history of nonappearance at 113
	150	+	commission proceedings or disruption of the commission's 114
	151	+	administrative process, including, but not limited to, delaying 115
	152	+	commission proceedings; and (E) the refusal to participate in settlement 116
	153	+	conferences conducted by a commission ombudsman in accordance 117
	154	+	with the commission's regulations. 118
	155	+	(4) Notwithstanding any provision of this subsection, [to the 119
	156	+	contrary,] in the case of an appeal to the commission of a denial by a 120 Substitute Bill No. 1221
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175		-	public agency alleges is a vexatious requester. Such petition shall be
176		-	sworn under penalty of false statement, as provided in section 53a-157b,
177		-	and shall detail the conduct which the agency alleges demonstrates a
178		-	vexatious history of requests, including, but not limited to: (A) The
179		-	number of requests filed and the total number of pending requests; (B)
180		-	the scope of the requests; (C) the nature, content, language or subject
181		-	matter of the requests; (D) the nature, content, language or subject
182		-	matter of other oral and written communications to the agency from the
183		-	requester; and (E) a pattern of conduct that amounts to an abuse of the
184		-	right to access information under the Freedom of Information Act or an
185		-	interference with the operation of the agency. Upon receipt of such
186		-	petition, the executive director of the commission shall review the
187		-	petition and determine whether it warrants a hearing. If the executive
188		-	director determines that a hearing is not warranted, the executive
189		-	director shall recommend that the commission deny the petition
190		-	without a hearing. The commission shall vote at its next regular meeting
191		-	after such recommendation to accept or reject such recommendation
192		-	and, after such meeting, shall issue a written explanation of the reasons
193		-	for such acceptance or rejection. If the executive director determines that
194		-	a hearing is warranted, the commission shall serve upon all parties, by
195		-	certified or registered mail or electronic transmission, a copy of such
196		-	petition together with any other notice or order of the commission. The
197		-	commission shall, after due notice to the parties, hear and either grant
198		-	or deny the petition [within] not later than one year after its filing. Upon
199		-	a grant of such petition, the commission may provide appropriate relief
200		-	commensurate with the vexatious conduct, including, but not limited
201		-	to, an order that the agency need not comply with future requests from
202		-	the vexatious requester for a specified period of time, but not to exceed
203		-	one year. Any party aggrieved by the commission's granting of such
204		-	petition may apply to the superior court for the judicial district of New
205		-	Britain, [within] not later than fifteen days [of] after the commission
206		-	meeting at which such petition was granted, for an order reversing the
207		-	commission's decision. Substitute Senate Bill No. 1221
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	163	+	public agency, the commission may, upon motion of such agency, 121
	164	+	confirm the action of the agency and dismiss the appeal without a 122
	165	+	hearing if it finds, after examining the notice of appeal and construing 123
	166	+	all allegations most favorably to the appellant, that (A) the agency has 124
	167	+	not violated the Freedom of Information Act, or (B) the agency has 125
	168	+	committed a technical violation of the Freedom of Information Act that 126
	169	+	constitutes a harmless error that does not infringe the appellant's rights 127
	170	+	under said act. 128
	171	+	(5) Notwithstanding any provision of this subsection, in the case of 129
	172	+	an appeal to the commission of a denial by a public agency where, after 130
	173	+	a hearing, the commission finds the public agency is engaging in a 131
	174	+	practice or pattern of conduct that constitutes an obstruction of the 132
	175	+	public's right to access information under the Freedom of Information 133
	176	+	Act or reckless, wilful or wanton misconduct with regard to the delay 134
	177	+	or denial of responses to requests for public records under said act, the 135
	178	+	commission may apply to the superior court for the judicial district of 136
	179	+	New Britain for further injunctive and equitable relief, damages, 137
	180	+	attorney's fees and costs, as the court may order. 138
	181	+	[(5)] (6) Notwithstanding any provision of this subsection, a public 139
	182	+	agency may petition the commission for relief from a requester that the 140
	183	+	public agency alleges is a vexatious requester. Such petition shall be 141
	184	+	sworn under penalty of false statement, as provided in section 53a-157b, 142
	185	+	and shall detail the conduct which the agency alleges demonstrates a 143
	186	+	vexatious history of requests, including, but not limited to: (A) The 144
	187	+	number of requests filed and the total number of pending requests; (B) 145
	188	+	the scope of the requests; (C) the nature, content, language or subject 146
	189	+	matter of the requests; (D) the nature, content, language or subject 147
	190	+	matter of other oral and written communications to the agency from the 148
	191	+	requester; and (E) a pattern of conduct that amounts to an abuse of the 149
	192	+	right to access information under the Freedom of Information Act or an 150
	193	+	interference with the operation of the agency. Upon receipt of such 151
	194	+	petition, the executive director of the commission shall review the 152
	195	+	petition and determine whether it warrants a hearing. If the executive 153 Substitute Bill No. 1221
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	202	+	director determines that a hearing is not warranted, the executive 154
	203	+	director shall recommend that the commission deny the petition 155
	204	+	without a hearing. The commission shall vote at its next regular meeting 156
	205	+	after such recommendation to accept or reject such recommendation 157
	206	+	and, after such meeting, shall issue a written explanation of the reasons 158
	207	+	for such acceptance or rejection. If the executive director determines that 159
	208	+	a hearing is warranted, the commission shall serve upon all parties, by 160
	209	+	certified or registered mail or electronic transmission, a copy of such 161
	210	+	petition together with any other notice or order of the commission. The 162
	211	+	commission shall, after due notice to the parties, hear and either grant 163
	212	+	or deny the petition [within] not later than one year after its filing. Upon 164
	213	+	a grant of such petition, the commission may provide appropriate relief 165
	214	+	commensurate with the vexatious conduct, including, but not limited 166
	215	+	to, an order that the agency need not comply with future requests from 167
	216	+	the vexatious requester for a specified period of time, but not to exceed 168
	217	+	one year. Any party aggrieved by the commission's granting of such 169
	218	+	petition may apply to the superior court for the judicial district of New 170
	219	+	Britain, [within] not later than fifteen days [of] after the commission 171
	220	+	meeting at which such petition was granted, for an order reversing the 172
	221	+	commission's decision. 173
	222	+	This act shall take effect as follows and shall amend the following
	223	+	sections:
	224	+
	225	+	Section 1 October 1, 2023 1-206(b)
	226	+
	227	+	GAE Joint Favorable Subst.
	228	+	JUD Joint Favorable
211	229