Quattro v. Vital Statistics Registrar, State of Connecticut, Department of Public Health
Under Connecticut General Statutes §7-51a(a), a member of the general public, who is 18 years of age or older, is permitted access to copies of marriage and death records and copies of fetal death records that are at least 100 years old. James Quattro appealed to the Freedom of Information Commission alleging that the Department of Public Health and its vital statistics registrar violated the Freedom of Information Act by denying him prompt access to inspect all indices of death and marriage records and actual death and marriage records maintained by the respondents. The FOIC found that while the indices do not contain confidential information, they are the respondents' official records. The respondents permit supervised access to ensure the records' integrity and provide access to one index at a time at a front counter. The respondents offered the complainant such access, but he sought access to all indices at the same time. Given the total number of indices, almost a thousand, it would be unreasonable to require the respondents to remove all indices from the vault and place them on the counter simultaneously. The FOIC found the respondents' policy of providing access one index at a time reasonable. For the actual death and marriage records, C.G.S. §7-51a(a) recognizes three classes of record seekers, each with different rights of access. The complainant testified that he requested access as a member of the public and that he did not have particular death or marriage records in mind when he made the request. The records he sought were both less and more than 100 years old. As a member of the public 18 years of age or older, the complainant was permitted access to copies of marriage and death records and copies of fetal death records that are at least 100 years old. Depending on the records' age, the respondents are statutorily required to make certain redactions. Given the respondents' statutory obligation to keep certain information confidential, including Social Security numbers, the requirement that the requestor identify with some specificity the record or records he wishes to inspect is reasonable. No FOIA violation was found. The complaint was dismissed.