ST. LOUIS — In a case testing the limits of Missouri’s Sunshine Law, the Missouri Court of Appeals has upheld a trial court ruling in favor of the city of St. Louis, which denied a request for public records due to a dispute over the requested file format.
The plaintiff, Phillip Weeks, submitted a request to the St. Louis Metropolitan Police Department (SLMPD) in July 2019, seeking electronic copies of traffic stop data from 2014 through 2018.
Specifically, he requested the data in an Excel workbook format, the opinion noted.
After months of back-and-forth clarification efforts, SLMPD informed Weeks that no existing records matched his request but offered to provide Traffic Analysis Reports instead, which he declined.
In response, Weeks filed a lawsuit in November 2019, alleging that the city had violated Missouri’s Sunshine Law by failing to provide the requested records.
The case went to trial in 2023, where Weeks presented expert testimony arguing that the city did possess the requested data, albeit in a different format.
Despite this, the trial court ruled in favor of the city, finding that it did not hold or maintain records in the specific format requested by Weeks. Weeks appealed the ruling.
The appellate court upheld the trial court’s decision, emphasizing that Weeks’ request specifically sought data in Excel format.
The court found that while SLMPD did possess the data in a different format—comma-separated values (.csv) files—the agency did not maintain records in the requested Excel format.
The judges ruled that the city was not obligated to create new records or alter existing ones to comply with a specific request.
The majority opinion noted in the standard of review, that the court would not overturn a trial court’s ruling unless it was clearly against the weight of the evidence. The judges determined that Weeks’ request, as written, was not clear enough to require the city to produce the data in a format it did not already maintain.
The ruling underscored that while Missouri’s Sunshine Law promotes government transparency, public bodies must be able to rely on the precise language of a records request when determining their obligation to respond.
The court ruled that Weeks’ failure to request the data in a format SLMPD maintained meant the city did not violate the law by denying the request.
Judge John P. Torbitzky issued a strongly worded dissent, arguing that the ruling undermines the intent of Missouri’s Sunshine Law.
He pointed out that the law is meant to ensure broad public access to government records and should be interpreted liberally in favor of transparency.
Torbitzky wrote that the city admitted to having the requested data in .csv format at the time of Weeks’ request.
He contended that refusing to release records solely because they were not in the precise format requested contradicts the purpose of open records laws.
He also noted that Weeks had not insisted on receiving the records only in Excel format but had merely expressed a preference for it.
The judge argued that requiring requesters to perfectly phrase their requests to match the city’s internal record-keeping practices places an undue burden on the public.
“The public should not be denied access to records based on an arbitrary technicality,” Torbitzky wrote. “This decision allows government agencies to withhold information simply by maintaining records in less accessible formats.”
The appellant was represented by Amy E. Breihan and Shubra Ohri.
The respondent was represented by Abby J. Duncan.
Attorneys declined to comment on the case.
Missouri Court of Appeals, Eastern District, District Four case number: ED112624