New York Times Co. v. Phh M. Health Services

Summary

The Supreme Court of Florida held that a private entity acting on behalf of a public agency, when uncertain of its agency status and seeking judicial clarification, does not unlawfully refuse record inspection under §119.12(1); consequently, attorney's fees are not awardable. The Court affirmed the appellate court's reversal of the fee award and adopted the totality‑of‑factors test from Schwab for determining agency status.