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Opinion

Opinion By: Gregory D. Stumbo, Attorney General; James M. Ringo, Assistant Attorney General

Open Records Decision

The issue presented in this appeal is whether Baptist Hospital East is a "public agency" for purposes of the Open Records Act. For the reasons that follow, we conclude that the hospital is not a public agency within the meaning of KRS 61.870(1), and is not subject to the Act.

By letter dated September 1, 2000, Victoria Kelley submitted an open records request to Baptist Hospital East requesting certain statistical information relating to deaths at the hospital and nurse to patient ratio.

On September 19, 2005, Ms. Kelley initiated an appeal to this office stating she had received no response from the hospital.

After receipt of notification of the appeal and a copy of the letter of appeal, Jessica L. Swim, Corporate Counsel, Baptist Healthcare System, provided this office with a response to the issues raised in the appeal. In her response, Ms. Swim advised that Baptist Hospital East is not subject to the Open Records Act as it is not a public agency as defined by the Act, rather it is a private, nonprofit corporation that operates an acute care hospital in Louisville, Kentucky.

The threshold issue presented in this appeal is whether Baptist Hospital East is a "public agency" for purposes of the Open Records Act. We conclude that the hospital is not a public agency within the meaning of KRS 61.870(1), and is not subject to the Act.

As Ms. Swim explained in her response to the letter of appeal, Baptist Hospital East is a private non-profit corporation and not a "public agency" within the meaning of Open Records Act. KRS 61.870(1). As such, it cannot be required to release its records, or to adhere to KRS 61.880(1), in response to a request for its records under the Open Records Act. 93-ORD-127. Accordingly, the actions of Baptist Hospital East relative to Ms. Kelley's request cannot be said to have violated the Act.

A party aggrieved by this decision may appeal it by initiating action in the appropriate circuit court pursuant to KRS 61.880(5) and KRS 61.882. Pursuant to KRS 61.880(3), the Attorney General should be notified of any action in circuit court, but should not be named as a party in that action or in any subsequent proceeding.

Distributed to:

Victoria Kelley1875 Logsdon CemeteryClarkson, KY 42726 Jessica L. SwimCorporate CounselBaptist Healthcare System4007 Kresge WayLouisville, KY 40207

LLM Summary
The decision addresses whether Baptist Hospital East qualifies as a 'public agency' under the Open Records Act. It concludes that the hospital, being a private non-profit corporation, does not meet the definition of a public agency as outlined in KRS 61.870(1) and is therefore not subject to the requirements of the Open Records Act. The decision cites a previous opinion (93-ORD-127) to support this interpretation but does not alter or directly rely on its reasoning for the current case's specific circumstances.
Disclaimer:
The Sunshine Law Library is not exhaustive and may contain errors from source documents or the import process. Nothing on this website should be taken as legal advice. It is always best to consult with primary sources and appropriate counsel before taking any action.
Requested By:
Victoria Kelley - Baptist Hospital East
Type:
Open Records Decision
Lexis Citation:
2005 Ky. AG LEXIS 163
Cites:
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