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Holladay v. Glass

Ark. Ct. App.November 8, 2017No. CV-17-159Cited 6 times
Plaintiff WinPulaski County Sheriff's Office$8,726.5 awarded
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Case Details

Judge(s)
Brandon J. Harrison
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Outcome

The court affirmed the circuit court's ruling that a prison transport manifest was not exempt from disclosure under Arkansas's FOIA "undisclosed investigation" exception and upheld an award of attorney's fees to the plaintiff.

What This Ruling Means

**What Happened** A worker named Holladay requested records from the Pulaski County Sheriff's Office under Arkansas's Freedom of Information Act (FOIA). Specifically, Holladay wanted to see a prison transport manifest - essentially a document showing when and how prisoners are moved between facilities. The Sheriff's Office refused to release this document, claiming it was part of an ongoing investigation that couldn't be disclosed to the public. **What the Court Decided** The court ruled in favor of Holladay. The judges determined that the prison transport manifest was not protected under Arkansas's FOIA exception for "undisclosed investigations." This meant the Sheriff's Office had to release the document. The court also ordered the Sheriff's Office to pay Holladay's attorney fees, totaling $8,726.50. **Why This Matters for Workers** This case strengthens workers' rights to access government records. When government employers try to hide documents by claiming they're part of secret investigations, courts will carefully examine whether that excuse is valid. Workers can use FOIA laws to obtain important workplace documents, and if the government wrongfully withholds records, they may have to pay the worker's legal costs. This creates accountability and transparency in government workplaces.

This summary was generated to explain the ruling in plain English and is not legal advice.

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