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Prison Health Services, Inc. v. Lakeland Ledger Pub. Co.

Citations: 718 So. 2d 204; 1998 WL 406293Docket: 97-05034

Court: District Court of Appeal of Florida; July 22, 1998; Florida; State Appellate Court

Narrative Opinion Summary

Prison Health Services, Inc. (PHS) appealed a trial court order requiring it to produce records related to a settlement agreement concerning the treatment of an inmate, following a public records request from the Lakeland Ledger Publishing Company. The court affirmed the trial court's decision, determining that PHS, through its contract with the Sheriff of Polk County to provide health care services for inmates, acted on behalf of a public agency. Consequently, records that would typically fall under the Florida Public Records Act are applicable to PHS, even though it is a private corporation. The trial court noted that PHS had acknowledged its obligation to comply with the Florida Public Records law in its contract, except for records explicitly exempted. The appellate court found that both the evidence presented and relevant law supported the trial court’s ruling, leading to the affirmation of the order.

Legal Issues Addressed

Contractual Acknowledgment of Public Records Obligations

Application: The private entity's acknowledgment in its contract of the obligation to comply with public records laws supports the applicability of such laws to the entity.

Reasoning: The trial court noted that PHS had acknowledged its obligation to comply with the Florida Public Records law in its contract, except for records explicitly exempted.

Judicial Affirmation Based on Evidence and Law

Application: The appellate court affirmed the trial court's order based on the sufficiency of evidence and the applicability of relevant legal principles.

Reasoning: The appellate court found that both the evidence presented and relevant law supported the trial court’s ruling, leading to the affirmation of the order.

Public Records Act Applicability to Private Entities

Application: The court determined that a private corporation contracted to perform services for a public agency is subject to the Florida Public Records Act when acting on behalf of the agency.

Reasoning: The court affirmed the trial court's decision, determining that PHS, through its contract with the Sheriff of Polk County to provide health care services for inmates, acted on behalf of a public agency.