Background
Joel Edward Chandler emailed St. Peter’s Academy’s principal and records custodian in March 2023 seeking electronic copies of public records concerning the charter school’s annual meetings and corporate filings. The custodian acknowledged receiving the email but testified that it went unread through inadvertence.
After receiving no response for more than a year, Chandler sent a certified letter in June 2024 and then sued to compel production under Florida’s Public Records Act. The School later mailed paper copies of the records. Following a bench trial, the circuit court ruled for the School, treating the June 2024 letter as the operative request and finding the later response reasonable.
The Court’s Holding
The Fourth District reversed and remanded. Under the Uniform Electronic Transactions Act, Chandler’s request was received when it entered the custodian’s designated email system in March 2023, even though the custodian had not read it. The trial court therefore erred by excluding that request from its timeline.
The court also held that the circuit court used the wrong legal standard by focusing on whether the custodian acted knowingly, willfully, or maliciously. For Chandler’s request for declaratory relief, the question is whether the School unjustifiably delayed making nonexempt records available; intent is not required. On remand, the court must assess reasonableness beginning with the March 2023 email, including whether website availability was timely and whether the School adequately complied with the request for electronic records.
Key Takeaways
- A public-records email is received when it reaches the recipient’s designated email system, whether or not someone reads it.
- A requester need not repeatedly follow up to make an agency responsible for responding.
- Unjustified delay in producing nonexempt public records can violate the Act without proof of willful or malicious conduct.
Why It Matters
The decision confirms that charter schools subject to Florida’s Public Records Act must promptly acknowledge and respond to requests sent to their designated email addresses. An overlooked inbox does not reset the statutory timeline.
The ruling also separates a records-access claim from statutory penalty provisions that require knowing or willful conduct, keeping the focus on whether the agency’s delay was justified.