Times Publishing Co. Inc. v. Michel

In Times Publishing Co., Inc. v. Michel, 159 Pa. Commw. 398, 633 A.2d 1233, 1239 (Pa. Cmwlth. 1993), a reporter requested access to written applications pertaining to licenses to carry firearms issued by an individual sheriff. The Court granted limited access to the documents, including the applicant's name, race, reason for requesting the license, personal references, and responses to background questions; we refused to disclose the applicant's address and social security number. Times Publishing, 633 A.2d at 1239. The Court held that the information was protected under the personal security exception, stating that access to addresses and social security numbers would constitute an invasion of privacy that would outweigh any public interest in dissemination. Id. The issue before the court was the extent to which information contained in applications to carry firearms was subject to disclosure under the former RTKL. The court analyzed the disclosure of home addresses under the personal security exception, mindful that personal security was defined as freedom from harm, danger, fear, or anxiety and required a determination that disclosure would be "intrinsically harmful." Noting the dangers associated with possession of firearms, the court concluded that the personal security exception applied. Ultimately, however, the court determined that, in deciding whether requested information is protected by the personal security exception to the law, the court must apply a balancing test, weighing privacy interests and the extent to which they may be invaded against the public benefits that may result from disclosure.