City of New Haven v. Freedom of Information Commission

Summary

The Supreme Court of Connecticut consolidated appeals by the Freedom of Information Commission and Susan Stone from a Superior Court judgment reversing the commission's order requiring New Haven to disclose attorney invoices listing only law-firm names and amounts billed for litigation over the East Shore waste-water treatment plant. The court held that the trial court exceeded the permissible scope of judicial review under the Uniform Administrative Procedure Act by substituting its judgment for the commission's, because the record contained no evidence—only counsel's arguments—that the invoices pertained to strategy and negotiations under General Statutes § 1-19 (b) (4). It further held that the commission's disclosure order was sustainable because the city failed to carry its burden of establishing any exemption, while expressly reserving whether such invoices could ever qualify as exempt under other circumstances. No separate opinions were filed.