Navarre v. South Washington County Schools

In Navarre v. South Washington County Schools, the Minnesota Supreme Court enforced the MGDPA against a public school district that had disclosed to the public information about a teacher under investigation:

The Minnesota Government Data Practices Act "regulates the collection, creation, storage, maintenance, dissemination, and access to government data" and "establishes a presumption that government data are public and are accessible by the public for both inspection and copying." Minn. Stat. § 13.01, subd. 3 (2000). Whether appellant disseminated personnel data in violation of the MGDPA involves our construction of the MGDPA, which is a question of law subject to de novo review. Doe v. Minnesota State Bd. of Med Exam'rs, 435 N.W.2d 45, 48 (Minn. 1989). "Personnel data are data that identify the employee who is the subject of the data." Demers v. City of Minneapolis, 468 N.W.2d 71, 73 (Minn. 1991). All personnel data not delineated by Minn. Stat. § 13.43, subds. 2 (Supp. 2001), 3 (2000), as public data are private data. Id; Minn. Stat. § 13.43, subd. 4 (2000). Public data includes, in part, "the existence and status of any complaints or charges against the employee, regardless of whether the complaint or charge resulted in a disciplinary action." Minn. Stat. § 13.43, subd. 2(a)(4). "The final disposition of any disciplinary action together with the specific reasons for the action and data documenting the basis of the action" are also public data, with a final disposition occurring once there is a final decision about the disciplinary action. Id., subd. 2(a)(5), 2(b).

Navarre v. S. Wash. Cty. Schs., 652 N.W.2d 9, 22 (Minn. 2002).