Sapp Roofing Co., Inc. v. Sheet Metal Workers' International Association

In Sapp Roofing Co., Inc. v. Sheet Metal Workers' International Association, 552 Pa 105, 713 A.2d 627 (1998), a plurality of the Supreme Court held that a private roofing contractor's payroll records, which had been submitted to the government in connection with the performance of a public project, were public records under the Law. The Court reasoned that these documents qualified as public records "because they are records evidencing a disbursement by the school district." Sapp Roofing, 522 Pa. at 110, 713 A.2d at 629.