, Sarah v. Easton, Town of - Public Schools (SPR 20260361)

The Commonwealth of Massachusetts William Francis Galvin, Secretary of the Commonwealth Public Records Division Manza Arthur Supervisor of Records February 12, 2026 SPR26/0361 Lisha Cabral Superintendent Easton Public Schools 48 Spooner Street North Easton, MA 02356 Dear Superintendent Cabral: I have received the petition of Sarah (requestor), appealing the response of the Easton Public Schools (School) to a request for public records. See G. L. c. 66 § 10A; see also 950 C.M.R. 32.08(1). On November 24, 2025, the requestor sought, “[a]ll emails, memoranda, internal communications, directives, or meeting notes exchanged between or among: Superintendent . . . ; Director of Student Services . . . ; [and] Human Resources Director . . .” The School provided responses on December 10, 2025, December 12, 2025, and January 8, 2026. Unsatisfied with the School’s responses, the requestor petitioned this office and this appeal, SPR26/0361, was opened as a result. The Public Records Law The Public Records Law strongly favors disclosure by creating a presumption that all governmental records are public records. G. L. c. 66, § 10A(d); 950 C.M.R. 32.03(4). “Public records” is broadly defined to include all documentary materials or data, regardless of physical form or characteristics, made or received by any officer or employee of any agency or municipality of the Commonwealth, unless falling within a statutory exemption. G. L. c. 4, § 7(26). It is the burden of the records custodian to demonstrate the application of an exemption in order to withhold a requested record. G. L. c. 66, § 10(b)(iv); 950 C.M.R. 32.06(3); see also Dist. Attorney for the Norfolk Dist. v. Flatley, 419 Mass. 507, 511 (1995) (custodian has the burden of establishing the applicability of an exemption). To meet the specificity requirement a custodian must not only cite an exemption, but must also state why the exemption applies to the withheld or redacted portion of the responsive record. One Ashburton Place, Room 1719, Boston, Massachusetts 02108 • (617) 727-2832• Fax: (617) 727-5914 sec.state.ma.us/pre • pre@sec.state.ma.us

Lisha Cabral SPR26/0361 Page 2 February 12, 2026 If there are any fees associated with a response a written, good faith estimate must be provided. See G. L. c. 66, § 10(b)(viii); see also 950 C.M.R. 32.07(2). Once fees are paid, a records custodian must provide the responsive records. The School’s December 10th, December 12th, and January 8th Responses In its December 10, 2025 response, the School stated the following: As a preliminary matter, Easton Public Schools objects to your public record request to the extent it seeks private information regarding employees…Your request may include employees’ intimate personal information surrounding leaves of absence generally for medical reasons, including but not limited to leaves under Family Medical Leave Act (FMLA). Moreover, the[r]e is no substantive public interest in disclosure of this information. …I have been advised that there are no memoranda, internal communications or directives or meeting notes in the possession or control of the Easton Public Schools encompassing these search terms other than what might be included in the emails among administrators. A preliminary search has revealed that a minimum of 423 emails, including attachments, were identified based upon the criteria in your request. Once the emails are identified, they must be converted from MBOX format before being read and potentially redacted based upon the privacy exemption noted above and/or other relevant exemptions or attorney/client privileged communications that might be discovered… We have determined that fourteen hours are required to complete the functions above. The District requires payment of $300 before proceeding… On December 10, 2025, the requestor narrowed her request, stating, “[t]o reduce the scope and cost, I would like to narrow my request as follows: [1] Limit the date range to October 15, 2025 – November 15, 2025[;] [2] Limit custodians to [three identified individuals][;] [3] Limit search terms to: coverage, administrative coverage, interim, redistribute, redistribution, operational impact, IEP coverage, special education leadership[;] [4] Exclude attachments, drafts, newsletters, calendar invites, general district- wide notifications, [and] any medical/FMLA-related content[;] [5] Include [a]ny emails or memos among the above custodians discussing: temporary coverage of Special Education administrative duties, interim role assignments, redistribution of responsibilities, IEP meeting coverage, [and] operation adjustments or continuity planning.

Lisha Cabral SPR26/0361 Page 3 February 12, 2026 In its December 12, 2025 response, the School stated, “[t]hank you for narrowing the request. We will look into it and respond as soon as possible.” On January 8, 2026, in an email to the School, the requestor stated, “I am writing to follow up on my narrowed public records request…As of today, I have not yet received a revised fee estimate, responsive records, a formal denial, or a request for an extension…” In its January 8, 2026 response, the School stated, “[w]e have received the reduced request. In light of the reductions you have proposed, we intend to forward the records responsive to this request within the next 10 business days at no cost.” Current Appeal In the requestor’s January 25, 2026 petition to this office, the requestor stated, “[d]espite good-faith efforts on my part, including narrowing the request and allowing additional time – the [School] has now exceeded multiple deadlines…” Timeframe for Providing Records G. L. c. 66, § 10(b) provides, in pertinent part, that if the magnitude or difficulty of a request unduly burdens the other responsibilities of the agency or municipality such that the agency or municipality cannot provide records within 10 business days, the agency or municipality must inform the requestor in writing within 10 business days. With respect to the timeframe to produce responsive records, the written response shall: identify a reasonable timeframe in which the agency or municipality shall produce the public records sought; provided, that . . . for a municipality the timeframe shall not exceed 25 business days following the initial receipt of the request for public records; and provided further, that the requestor may voluntarily agree to a response date beyond the timeframes set forth herein. G. L. c. 66, § 10(b)(vi). Where the requestor submitted the narrowed request on December 10, 2025, and the School has not provided responsive records, I find the School has not met its burden in responding to the request in accordance with G. L. c. 66, § 10(b). Consequently, the School must provide an estimated date as to when it intends to provide the responsive records. See G. L. c. 66, § 10(a) (records must be provided without unreasonable delay). To the extent possible, the School must provide responsive records on a rolling basis. Conclusion Accordingly, the School is ordered to provide the requestor with a response to the request, provided in a manner consistent with this order, the Public Records Law, and its

Lisha Cabral SPR26/0361 Page 4 February 12, 2026 Regulations within ten (10) business days. A copy of any such response must be provided to this office. It is preferable to send an electronic copy of the response to this office at pre@sec.state.ma.us. The requestor may appeal the substantive nature of the School’s response within ninety days. See 950 C.M.R. 32.08(1). Sincerely, Manza Arthur Supervisor of Records cc: Sarah