Missouri Court of Appeals, Western District / Nov 12, 2019
Paula Wyrick vs. Teresa Henry
Paula Wyrick sought records from Teresa Henry, the City Clerk for Raytown, Missouri, under the Sunshine Law after Wyrick's mother died in a car accident. Henry denied the requests, asserting a litigation exception. The trial court found Henry knowingly and purposefully violated the Sunshine Law, ordered disclosure, imposed a civil penalty, and awarded attorney's fees. The appellate court affirmed the trial court's judgment, holding that the litigation exception does not apply based on the requestor's identity or the records' potential relevance to litigation, and that Henry's violations were knowing and purposeful. The case was remanded for consideration of appellate attorney's fees.