Director orders limited disclosure in Wilkinson appeals, upholds most of Davis School District's records classifications

Director Pearson granted in part and denied in part consolidated appeals filed by Miss Wilkinson challenging Davis School District's response to two GRAMA requests, the director said on the record.

Miss Wilkinson, representing herself, told the panel the district's production largely consisted of documents she already possessed and that the district failed to produce internal communications, meeting notes and other records that would show how important personnel decisions were made. "Did the district conduct a reasonable search? Did it properly identify the records it found? Were those records properly classified?" she asked the director.

The district, represented by Onofrio, said it searched likely custodians, searched relevant systems and supplemented its response during the administrative appeal, producing an additional responsive email found on re-review. "The district searched the custodians most likely to possess responsive records, searched the systems where responsive records would ordinarily be maintained," Onofrio said, asking the director to affirm the district's access determinations.

Pearson said he reviewed the records provided for in-camera and found that, overall, the district had conducted a reasonable search and properly classified most withheld material under GRAMA and FERPA. However, he identified several pages that should be released with redactions to protect student privacy. "So this appeal is granted in part and denied in part," Pearson said, and ordered disclosure of specific Bates-numbered pages (identified to the parties) with redaction where necessary. He gave the district 30 days from the written decision to produce those pages and said a written decision would follow within seven business days. The parties have 30 calendar days from that written decision to appeal to district court.

Why it matters: The ruling illustrates the balancing test GRAMA requires when records intersect with student-privacy protections under FERPA. The director's in-camera review authorized a limited disclosure while upholding most of the district's withholdings, signaling deference to privacy protections where redaction could not preserve intelligibility.

Next steps: The director will circulate a written order in seven business days specifying the pages and permissible redactions; the district must produce the ordered pages within 30 days or the parties may appeal to district court.