When a City Cannot Say “No”
What City of Bridgeport v. Freedom of Information Commission Teaches About Public Records
Connecticut’s Freedom of Information Act is built on a simple idea. Government records belong to the public unless the law clearly says otherwise. The Appellate Court’s decision in City of Bridgeport v. Freedom of Information Commission is a reminder that courts take that idea seriously, even when compliance is inconvenient for a municipality.
The Dispute
A requester sought records from the City of Bridgeport related to a municipal matter. The City refused to produce certain documents, arguing that they were exempt from disclosure under FOIA. The Freedom of Information Commission disagreed and ordered disclosure. The City appealed. The Appellate Court affirmed the Commission.
The Court’s Core Message
The Court emphasized a foundational principle of Connecticut FOIA law. Exemptions are narrow, and the burden is always on the public agency to prove that an exemption applies. It is not enough for a city to assert that records are sensitive, internal, or related to government operations. The agency must show, with evidence, that the records squarely fall within a statutory exemption. If the exemption does not fit cleanly, disclosure is required.
No Shortcut Through Labels
One of the City’s core arguments relied on how the records were characterized internally. The Court rejected that approach. Labels do not control. Substance does. If a document relates to public business and is maintained or kept on file by a public agency, it is a public record unless a specific exemption applies. Calling something “internal,” “preliminary,” or “informal” does not remove it from FOIA. This is a recurring mistake in municipal practice.
Deference to the FOI Commission
The decision also reinforces the significant deference courts give to the Freedom of Information Commission. The Commission is the fact finder. When it evaluates evidence, weighs credibility, and applies FOIA exemptions, courts will not reweigh that record on appeal. For municipalities, this means the real fight happens at the Commission level. Weak records and unsupported claims rarely improve on appeal.
Why This Case Matters
For cities and towns, the takeaway is straightforward. FOIA compliance requires discipline. Agencies must know what records they have, understand which exemptions actually apply, and be prepared to justify nondisclosure with evidence. For requesters, the case confirms that Connecticut courts remain strongly pro transparency. When an agency stretches an exemption beyond its limits, the law provides meaningful recourse. FOIA is not a technical nuisance. It is a core accountability statute. City of Bridgeport v. Freedom of Information Commission underscores that courts expect municipalities to treat it that way.
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Disclaimer: This blog is for informational purposes only and does not constitute legal advice. Reading this post does not create an attorney-client relationship. Every case is different, and you should consult a licensed attorney for advice regarding your specific situation.