Bd. of Trs., Jacksonville Police & Fire Pension Fund v. Lee
Annotate this CaseCurtis Lee requested public records from the Board of Trustees, Jacksonville Police & Fire Pension Fund (Pension Fund), which imposed certain conditions before allowing Lee to inspect and photocopy the records. Lee sought declaratory relief alleging that the conditions and fees were not legally valid. The trial court determined that two conditions were imposed in violation of Fla. Stat. 119.07. The First District Court of Appeal affirmed. Lee then moved for attorney’s fees under Fla. Stat. 119.12. The trial court denied the request. The First District reversed, concluding that the lower court erred in determining that Lee was not entitled to attorney’s fees because the Public Fund’s violation was neither knowing, willful, nor done with malicious intent. The Supreme Court approved the decision, holding (1) a prevailing party is entitled to statutory attorney’s fees under the Public Records Act when the trial court finds that the public agency violated a provision of the Act in failing to permit a public record to be inspected or copied; and (2) there is no additional requirement that a trial court find that the public agency did not act in good faith, acted in bad faith, or acted unreasonably before awarding attorney’s fees.
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