Connolly, Katherine v. Holbrook, Town of - Town Administrator (SPR 20260414)

The Commonwealth of Massachusetts William Francis Galvin, Secretary of the Commonwealth Public Records Division Manza Arthur Supervisor of Records February 18, 2026 SPR26/0414 Anne Mahoney Town Administrator Town of Holbrook 50 North Franklin Street Holbrook, MA 02343 Dear Ms. Mahoney: I have received the petition of Katherine Connolly appealing the response of the Town of Holbrook (Town) to a request for public records. See G. L. c. 66, § 10A; see also 950 C.M.R. 32.08(1). On January 14, 2026, Ms. Connolly requested: …the 2025 salary information for all Town of Holbrook employees, including the school department and HCAM employees. Please provide this information requested, Departmental Wage Reports, showing employee names, position, regular, overtime and additional pay. … An electronic copy emailed to my email address is requested. The Town responded on January 21, 2026. Unsatisfied with the response, Ms. Connolly petitioned this office and this appeal, SPR26/0414, 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 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

Anne Mahoney SPR26/0414 Page 2 February 18, 2026 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. 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 Town’s January 21st Response In its January 21, 2026 response, the Town provided responsive records and stated, “[p]lease find attached the Departmental Wage Reports for 2025, which include employee names, positions, and amounts for regular, overtime, and additional pay.” Current Appeal In her appeal petition, Ms. Connolly contends, “[t]he [Town’s] response for Town of Holbrook 2025 Departmental Wage Reports did not provide the information in the requested format. I have attached the 2024 Town of Holbrook Departmental Wage Report provided by the Town to my public records request dated January 14, 2025, as an example of the format requested.” In an email to this office on February 17, 2026, Ms. Connolly clarified, “[t]he 2025 reports don’t show totals by employee or departments.” Possession, Custody, or Control; Preferred Format The duty to comply with requests for records extends to those that exist and are in the possession, custody, or control of the custodian of records at the time of the request. See G. L. c. 66, § 10(a)(ii). Additionally, in accordance with the Public Records Law, custodians are expected to use their superior knowledge of the records in their custody to assist requestors in obtaining the desired information. See 950 C.M.R. 32.04(5). The Town is advised that a records access officer must, to the extent feasible, provide public records to a requestor in electronic format unless the record is not available in electronic form or the requestor does not have the ability to receive or access the records in electronic format and if feasible, in the requestor’s preferred format. In the absence of a preferred format, the records must be provided in a searchable machine-readable form. See 950 C.M.R. 32.04(5)(d). Based on the Town’s response, and in conjunction with the information provided in Ms. Connolly’s appeal, I find that it is unclear whether the Town possesses additional records responsive to the request. Specifically, it is unclear whether the Town possesses the 2025 Departmental Wage Reports in the format described by Ms. Connolly. The Town must clarify this matter.

Anne Mahoney SPR26/0414 Page 3 February 18, 2026 Conclusion Accordingly, the Town is ordered to provide Ms. Connolly with a response to the request, provided in a manner consistent with this order, the Public Records Law, and its Regulations within ten 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. Ms. Connolly may appeal the substantive nature of the Town’s response within ninety days. See 950 C.M.R. 32.08(1). Sincerely, Manza Arthur Supervisor of Records cc: Katherine Connolly