Barbara T. Wilson v. Theodore D. Mcneal

Respondents, the Pulitzer Publishing Company (Pulitzer) and Barbara T. Wilson (Wilson), in separate suits against appellants, members of the St. Louis Board of Police Commissioners (Board) were granted injunctions by the trial court, enjoining the Board, among other things, from denying respondents access to a report made by the Bureau of Inspections of the St. Louis Police Department pertaining to an investigation into the death of Joseph Lee Wilson. The Board has appealed from the judgments granting the injunctions. Upon motion, the cases were consolidated for appeal. The judgments are reversed and remanded with instructions to dissolve the injunctions. This is a case of first impression under Missouri's Sunshine Law, Chapter 610, RSMo C*m. Supp. 1975. The question to be answered is whether the exemptions from disclosure authorized in § 610.025 1 are limited in any way as to time. This court holds that an investigatory record, closed as authorized in § 610.025(4) is not required to be opened to the public after the investigation is concluded and a final decision made to take no action based on the report.