Indianapolis Star v. Trustees of Indiana University

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Indianapolis Star v. Trustees of Indiana University was a case before the Indiana Court of Appeals in 2003 concerning public records at a state university.

Important precedents[edit]

This case established a number of important precedents:
1.) That deliberative and personal information should be redacted, if possible, and the remaining information released to the public.
2.) That police investigation records retain their exempt status despite a lack of intention to prosecute.

Background[edit]

• In the spring of 2000, Indiana University basketball coach, Bobby Knight was accused of and investigated for mistreatment of players including physical violence and verbal threats.
• The Indianapolis Star requested all of the documents associated with the investigation, including witness reports, video tapes of practices and memo's concerning investigation results.
• On May 15, 2000, the University announced its intention to discipline and sanction Knight based on the results of the investigation which were delivered to the board in closed meetings on May 3 and May 14. The board summarized the results of the investigation and laid out there intended sanctions in a document entitled “Knight Sanctions”, which was released to the press^[1].
• In September of 2000, Knight was again accused of abuse of a student. On this occasion, the Indiana University Police Department investigated the case. They delivered the results of the investigation to the University. While no charges were filed, the results of the investigation influenced the boards decision to terminate Knight's contract. The records of this investigation were held by the police department.
• On May 18, 2000, the Star requested all documents associated with the first investigation into Knight. The board denied the request and instead submitted the memo which had been released to the public at the time. The board claimed that the information was exempt as "attorney work product" and under various privacy and investigation exemptions found within the Indiana Access to Public Records Act.
• On October 16, 2000, The Star requested the investigation material from the second investigation and was again rejected.
• The Star filed suit on January 2, 2001, and on November 5, 2001 the trial court ruled in favor of the board.
• The Star appealed the decision.^[1]

Ruling of the court[edit]

The trial court ruled in favor of the University and sealed the documents in question. The court determined that the documents were exempt under the exemptions for investigation records, the federal exemption for students, and the deliberative process exemption.^[1]

The Court of Appeals affirmed the trial courts decision with regard to the police investigation but overturned the remainder, remanding the decision to the trial court for further review.

The Court of Appeals began by affirming the trial courts decision concerning the investigation records held by the IUPD. The court determined that the exception for police investigation records found in Indiana statute 5-14-3-4(b)(1) applied to the Knight investigation even though there was no intention to prosecute Knight. The court also determined that the federal Family Educational Rights and Privacy Act did protect any information pertaining to students within the University's investigation. However, the court felt that by redacting student information, some of the documents requested by the star could be legitimately released. The court remanded the decision on what to redact to the trial courts for further review. The court went on to establish that some of the records contained in the investigation files were deliberative in nature and thus exempt. However, the court disagreed with the trial courts decision to exempt the entire document, and instead favored redacting deliberative information and leaving the purely facutal information that was subject to release. Based on these facts, the Court of Appeals affirmed only a small part of the trial courts decision and remanded the remainder for reconsideration and redaction of exempt material. The court ordered the remaining factual material, stripped of student information, released to the press.^[1]

Associated cases[edit]

See also[edit]

• Indiana Access to Public Records Act

External links[edit]

• Ruling of the Court

Footnotes[edit]