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Opinion

Opinion By: Daniel Cameron,Attorney General;James M. Herrick,Assistant Attorney General

Open Records Decision

Inmate Wayne Bodytko ("Appellant") sent an open records request to Community Transitional Services, LLC ("CTS"), for copies of certain records relating to his time as a resident at the CTS facility. CTS denied Appellant's request on the grounds that it was a private entity not subject to the Act.

CTS is a private limited liability company operating a halfway house in Louisville, Kentucky, under a contract with the Kentucky Department of Corrections ("DOC"). On appeal, Appellant offers no evidence that CTS is a "public agency" as defined by KRS 61.870(1).

Under KRS 61.870(1)(h), a private entity may be considered a "public agency," and therefore subject to the Act, if twenty-five percent (25%) of the funds it expends in a fiscal year are derived from state or local funds. "However, any funds derived from a state or local authority in compensation for goods or services that are provided by a contract obtained through a public competitive procurement process shall not be included in the determination of whether a [private entity] is a public agency under this subsection[.]" KRS 61.870(1)(h).

In 17-ORD-106 (copy attached), this Office found that CTS was not a public agency because its contract was obtained through a public competitive procurement process. Here, CTS affirms that this is still the case, and Appellant offers no proof to the contrary. Since the analysis in 17-ORD-106 is directly on point, this Office adopts that decision as if fully set forth herein. As a private entity not covered by KRS 61.870, CTS was not required to comply with the provisions of 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 shall be notified of any action in circuit court, but shall not be named as a party in that action or in any subsequent proceedings.

LLM Summary
The decision concludes that Community Transitional Services, LLC (CTS), a private entity operating a halfway house under contract with the Kentucky Department of Corrections, is not a public agency as defined by KRS 61.870(1). This determination is based on the fact that CTS's contract was obtained through a public competitive procurement process, which excludes the funds received under such a contract from being considered in determining public agency status under KRS 61.870(1)(h). The decision follows the reasoning and conclusion of a previous decision, 17-ORD-106, which found that CTS was not a public agency.
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:
Wayne Bodytko
Agency:
Community Transitional Services, LLC
Type:
Open Records Decision
Lexis Citation:
2020 KY. AG LEXIS 104
Cites:
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