This case required the Commonwealth Court to determine whether or not a county commissioner’s handwritten notes regarding phone conversations with private citizens, which were never relied on for official action, constituted public records under Pennsylvania’s Right-to-Know Law (RTKL).  Ultimately, the court held that these notes did not document a transaction or official business activity under the RTKL.  Therefore, it affirmed the trial court’s decision that the notes were not subject to disclosure.

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