A Florida court has reversed a lower court's decision in a case involving a public records request made by Joel Edward Chandler against St. Peter's Academy, Inc. The District Court of Appeal of Florida ruled on August 19, 2026, that Chandler's rights under the Florida Public Records Act were violated when the school did not respond to his request for records. This ruling could have significant implications for how public charter schools handle records requests in the future.
The case, identified by docket number 4D2025-2648, centers on Chandler's efforts to obtain electronic copies of public records related to the school’s annual meetings and corporate filings. The court's decision highlights the importance of transparency and accountability in public institutions, particularly in the realm of education.
Chandler's dispute with St. Peter's Academy began in March 2023 when he emailed the school's principal, requesting specific public records. Despite the principal confirming that she received the email, there was no response. More than a year later, Chandler sent a certified letter reiterating his request, which prompted the school to respond by sending paper copies of the records, rather than the electronic copies he had requested. Chandler argued that this did not satisfy his request, leading him to file a complaint against the school.
The initial response from the school claimed that the requested documents were readily available on their website and that copies had been mailed to Chandler. However, Chandler maintained that the lack of an electronic response was a failure to comply with the Public Records Act. The school later amended its response, raising defenses that included failure to state a claim and improper purpose.
After a bench trial, the lower court ruled in favor of St. Peter's Academy, concluding that the school had not unjustifiably delayed the production of records. The court emphasized that Chandler had not followed up for fourteen months after his initial request, suggesting that both the requester and the agency share responsibility for effective communication regarding public records requests.
However, the District Court of Appeal disagreed with this assessment. In its ruling, the court stated, "The trial court overlooked the initial request and applied an incorrect legal standard." The judges emphasized that the Public Records Act requires agencies to promptly acknowledge and respond to requests, and that unjustified delay is a violation of the law.
The court highlighted that Chandler's email in March 2023 constituted an official request for records, which the school was obligated to respond to in a timely manner. The judges noted that the trial court had erred by failing to consider the March email as the operative receipt date for Chandler's request. The court further clarified that the requirement for a finding of willful or knowing failure to comply with the law was not necessary in this case, as the focus was on whether the delay in providing the records was justified.
As a result of the ruling, the court reversed the lower court's judgment and remanded the case for further proceedings. The trial court must now assess whether St. Peter's Academy unlawfully delayed or otherwise violated the Public Records Act, particularly regarding the format in which the records were provided.
This ruling is significant as it reinforces the rights of individuals to access public records and holds public agencies accountable for their obligations under the law. It underscores the importance of timely responses to records requests, particularly in the context of public education.
Moving forward, this decision may influence how charter schools and other public agencies handle public records requests. It establishes a clearer expectation for agencies to respond promptly and adequately to requests, which could lead to increased transparency in public affairs.
As for what’s next, it remains to be seen whether St. Peter's Academy will appeal the ruling. The court's decision has opened the door for further examination of the school's compliance with the Public Records Act, and any subsequent findings could set important precedents for similar cases in the future.