Salt Lake City Corp. v. Jordan River Restoration Network
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The Supreme Court affirmed the judgment of the district court ruling in favor of Salt Lake City Corporation (City) in this dispute over whether the City’s denial of Jordan River Restoration Network’s (JRRN) fee waiver request with regard to the City’s grant of JRRN’s request for documents, holding that any error was harmless.
JRRN and its founder (collectively, JRRN) filed a request with the City seeking every document related to the construction of a sports complex and asked the City to provide the documents without charge. The City granted the document request but denied the fee waiver request. The City Records Appeals Board ordered the City to provide the requested documents at no charge.The State Records Committee also ruled in JRRN’s favor. On judicial review, the district court upheld the City’s decision to deny the fee waiver, concluding that the fee waiver denial was reasonable. The Supreme Court affirmed, holding (1) the district court conducted the review contemplated by the Government Records Access and Management Act; and (2) while the court made some procedural errors, each error was harmless.
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