Chandler v. St. Peter's Academy, Inc.
Chandler sued a public charter school under Florida's Public Records Act after his March 2023 emailed records request went unanswered for over a year; the trial court effectively disregarded the email, faulted Chandler for not following up, and found no willful or malicious conduct by the records custodian. The Fourth District reversed, holding that under the Uniform Electronic Transactions Act the request was objectively received when it entered the custodian's designated email inbox, that the Act places the duty to acknowledge and respond on the agency alone, and that no finding of knowing or willful violation was required for the relief sought.
Key facts
- Chandler submitted a public records request by email to St. Peter's Academy, a public charter school, in March 2023, but received no response for over a year.
- The trial court dismissed the Public Records Act claim, finding that Chandler had not adequately followed up on his request and that the school's records custodian had not acted willfully or maliciously in failing to respond.
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Why it matters
This opinion supplies a concrete rule for the increasingly common dispute over emailed public records requests: UETA's receipt provisions control, so an agency cannot escape liability by claiming the custodian never… — full analysis with a trial
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