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Opinion

Opinion By: Jack Conway, Attorney General; Amye L. Bensenhaver, Assistant Attorney General

Open Records Decision

This matter having been presented to the Office of the Attorney General in an open records appeal, and the Attorney General being sufficiently advised, we find that Kentucky State Penitentiary did not violate the Open Records Act by conditioning inmate Anthony Sadler's right to obtain copies of all records relating to Administrative Control Unit 90 day reviews, beginning in March 2010 to the present, on his ability to pay for copies of those records. It is the decision of this office that Friend v. Rees, 696 S.W.2d 325 (Ky. App. 1985) and 99-ORD-30 are dispositive of the issue on appeal. Pages 2 and 3 of the latter open records decision are particularly instructive in this regard. The Open Records Act contains no provision for waiver of the prepayment requirements found at KRS 61.872(3)(b) and KRS 61.874(1) for indigent inmates, and KSP did not violate the Act in denying Mr. Sadler's request on the basis that he has insufficient funds in his inmate account to defray the cost of copies. The facility's actions may work a hardship on Mr. Sadler but are consistent with the Open Records Act and the rule announced in Friend v. Rees, above.

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:

Anthony Sadler, # 15198Amy V. Barker

LLM Summary
The decision concludes that the Kentucky State Penitentiary did not violate the Open Records Act by conditioning inmate Anthony Sadler's right to obtain copies of records on his ability to pay for them. It references 99-ORD-030 as a key precedent that supports the ruling that there is no provision in the Open Records Act for waiving prepayment requirements for indigent inmates, thus upholding the facility's decision to deny Mr. Sadler's request based on insufficient funds.
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Requested By:
Anthony Sadler
Agency:
Kentucky State Penitentiary
Type:
Open Records Decision
Lexis Citation:
2011 Ky. AG LEXIS 78
Cites:
Forward Citations:
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