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Massa, J.
WTHR-TV sought information about a Hamilton Southeastern Schools (HSE) employee under Indiana Code section 5-14-3-4(b)(8). That statute requires public agencies to disclose certain types of information in public employee personnel files, including the “factual basis” for some disciplinary actions. Following a contentious back-and-forth, HSE provided WTHR with a compilation of the requested information, but not the underlying documents in the personnel file.
WTHR sued, arguing it was entitled to the underlying documents and that HSE’s factual basis for the employee’s discipline was insufficient. The trial court sided with HSE on both issues, and an appellate panel affirmed. We conclude WTHR was not entitled to the underlying documents because an agency may compile the required information into a new document. We also conclude that a “factual basis” must be a fact-based account of what caused the discipline; it cannot be a bald conclusion, which is what HSE provided. Accordingly, we affirm in part, reverse in part, and remand.
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The Indiana Access to Public Records Act governs public records requests and “is intended to ensure Hoosiers have broad access to most government records.” Evansville Courier & Press v. Vanderburgh Cnty. Health Dep’t, 17 N.E.3d 922, 928 (Ind. 2014). Although it creates a right to “inspect and copy the public records of any public agency,” I.C. § 5-14-3- 3(a), that right is not absolute. The Act contains “a myriad of broad exceptions.” Robinson v. Ind. Univ., 659 N.E.2d 153, 156 (Ind. Ct. App. 1995), trans. denied. Relevant here, the personnel file exception excepts from the general “inspect and copy” requirement the “[p]ersonnel files of public employees and files of applicants for public employment, except for” three categories of information. I.C. § 5-14-3-4(b)(8). These categories are exceptions to the exception. We now hold that the personnel file exception only requires public agencies to disclose those three categories of information, which can be done by compiling them into a new document. And we hold that the required “factual basis” for discipline must contain facts about the employee’s acts that caused the discipline.
I. Indiana Code section 5-14-3-4(b)(8) requires public agencies to provide certain types of information, but it does not require them to provide the underlying documents.
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Indiana Code section 5-14-3-4 provides mandatory and discretionary exceptions to the general “inspect and copy” requirement. The personnel file exception is discretionary: An agency may refuse to disclose public employee personnel files. I.C. § 5-14-3-4(b)(8). However, that exception contains three exceptions of its own. The first is basic identifying information: “the name, compensation, job title, business address, business telephone number, job description, education and training background, previous work experience, or dates of first and last employment of present or former officers or employees of the agency.” I.C. § 5-14-3-4(b)(8)(A). The second is “information relating to the status of any formal charges against the employee.” I.C. § 5-14-3-4(b)(8)(B). And the third is “the factual basis for a disciplinary action in which final action has been taken and that resulted in the employee being suspended, demoted, or discharged.” I.C. § 5-14-3-4(b)(8)(C). An agency cannot withhold information identified in those three exceptions. There is also a special provision for employees accessing their own information: “However, all personnel file information shall be made available to the affected employee or the employee’s representative.” I.C. § 5-14-3-4(b)(8). Finally, the personnel file exception clarifies that it “does not apply to disclosure of personnel information generally on all employees or for groups of employees without the request being particularized by employee name.” Id.
The three exceptions identify specific information that must be turned over. They do not identify specific documents. For example, agencies must only turn over a “job description,” not an original job posting. I.C. § 5-14- 3-4(b)(8)(A). The specific information can be conveyed without providing the underlying documents. Other portions of the Act indicate that agencies are only required to turn over information. Another discretionary exception provides that it “does not apply to that information required to be available for inspection and copying under” the personnel file exception. I.C. § 5-14-3-4(b)(12) (emphasis added). The personnel file exception itself requires “affected employee[s]” be able to access “personnel file information,” not the underlying documents. I.C. § 5-14-3- 4(b)(8). The Act constantly references “information” in personnel files, not documents. The personnel file exception means that although public agencies generally do not have to disclose public employee personnel files, they must disclose certain categories of information found in those files.
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HSE was not required to turn over the underlying documents in Wimmer’s personnel file. Thus, it complied with the Act when it compiled the necessary information into a new document and provided that document to WTHR.
II. Indiana Code section 5-14-3-4(b)(8) requires public agencies to provide a fact-based account of what led to an employee’s discipline.
Although an agency may compile the required information from a personnel file into a new document, it must still provide sufficient information. Here, there is no dispute that HSE sufficiently conveyed the first two types of required information—identifying information and information about formal charges. I.C. § 5-14-3-4(b)(8)(A)–(B). At issue is whether HSE provided a sufficient “factual basis” for Wimmer’s discipline. I.C. § 5-14-3-4(b)(8)(C).
The Act does not define “factual basis,” so we give that term its plain meaning. ESPN, Inc., 62 N.E.3d at 1195. The Court of Appeals here, relying on dictionary definitions, found the plain meaning of “factual basis” to be “a fact-based account of what led to the discipline.” WTHR-TV, 167 N.E.3d at 318. We agree with this definition and adopt it. However, it does not provide courts with much guidance for evaluating agency responses.
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HSE’s most comprehensive “factual basis” was that “Mr. Wimmer was suspended for five days without pay on December 14, 2016 due to not implementing instructions for classroom management strategies consistent with Board of School Trustees Policy G02.06.” Appellant’s App. Vol. II, p.65. It provides no facts about Wimmer’s actions that led to his suspension. It only concludes that he violated a broad policy. It does not even say when he violated that policy. A reasonable person would not know what Wimmer did to merit discipline, only that HSE decided to discipline him because it decided he violated a policy.
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HSE’s “factual basis” was merely a bald conclusion that Wimmer violated a broad policy. It did not contain facts about Wimmer’s actions that would allow a reasonable person to understand why he was suspended. HSE’s “factual basis” was insufficient.
Conclusion
We affirm the trial court’s conclusion that HSE complied with the Act by providing a compilation of information. However, we reverse its conclusion that HSE provided a sufficient factual basis. Accordingly, we remand for further proceedings consistent with this opinion.
Rush, C.J., and David, Slaughter, and Goff, JJ., concur.