The Commonwealth Court was required to construe Pennsylvania’s Private Road Act to determine whether or not a private road should be opened for public use. In holding that it should be opened, the court found that the petitioner’s property was landlocked and that the road would serve a public purpose.
This case required the Commonwealth Court to decide whether video recordings from cameras on buses can be exempt under the “noncriminal investigation” exemption to Pennsylvania’s Right-to-Know Law (the “RTKL”). The Commonwealth Court held that a video recording taken prior to the start of an agency investigation can qualify under the noncriminal investigation exemption of the RTKL when it is downloaded or viewed for purposes of that investigation. As a result, the Port Authority of Allegheny County (the “Port Authority”) did not have to disclose video recordings downloaded in relation to a property damage claim filed against it.