Shea, Sheila v. Worcester, City of (SPR 20261342)

The Commonwealth of Massachusetts William Francis Galvin, Secretary of the Commonwealth Public Records Division Manza Arthur Supervisor of Records April 16, 2026 SPR26/1342 Michael Manning Records Access Officer City of Worcester 455 Main Street Worcester, MA 01609 Dear Mr. Manning: On April 13, 2026, this office received your petition on behalf of the City of Worcester seeking an extension of time to produce records. G. L. c. 66, § 10(c); G. L. c. 66, § 10(d)(iv); see also 950 C.M.R. 32.06(4). As required by law, it is my understanding that the City furnished a copy of the petition to the requestor, Sheila F. Shea. G. L. c. 66, § 10(c); G. L.c. 66, § 10(d)(iv)(2). On March 16, 2026, Ms. Shea requested the following: [1] Definitions, parameters, and time frame Item 1 concerns district-maintained records associated with the administrative internships completed during the 2024– 2025 school year under the supervision of [an identified individual]. To assist in identifying the relevant internship placements, the following candidates are identified based on Administrator Licensure Verification documentation [an identified individual]… [2] Search terms To assist with retrieval of electronic records where applicable, the following search terms may be used: Primary identifiers [an identified individual] Internship and licensure terms internship administrative internship administrator internship mentor mentorship licensure administrator licensure PAL practicum Administrative supervision terms supervision observation evaluation internship hours internship verification These search terms are illustrative and are provided solely to assist the City in locating responsive records. The City may utilize additional search methods consistent with its superior knowledge of its record systems[;] [3] Record systems likely to contain responsive records Because [sic] the internships referenced above were supervised by [an identified individual] in her official capacity as mentor, responsive records may reasonably be expected to exist 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

Michael Manning SPR26/1342 Page 2 April 16, 2026 within record systems maintained in connection with her official duties. These may include, for example, [an identified individual]’s district email account, electronic calendar, and any district-maintained files or shared drives used in connection with the supervision or verification of administrative internship experiences. The licensure verification documentation reflects that the administrative internship experiences collectively required approximately 1,000 hours of field-based supervision during the 2024– 2025 school year. In an email to the Department on April 13, 2026, Ms. Shea objected to the petition. Petition for an Extension of Time Under the Public Records Law, upon a showing of good cause, the Supervisor of Records (Supervisor) may grant a single extension to an agency not to exceed 20 business days and a single extension to a municipality not to exceed 30 business days. In determining whether there has been a showing of good cause, the Supervisor shall consider, but shall not be limited to considering: (i) the need to search for, collect, segregate or examine records; (ii) the scope of redaction required to prevent unlawful disclosure; (iii) the capacity or the normal business hours of operation of the agency or municipality to produce the request without the extension; (iv) efforts undertaken by the agency or municipality in fulfilling the current request and previous requests; (v) whether the request, either individually or as part of a series of requests from the same requestor, is frivolous or intended to harass or intimidate the agency or municipality; and (vi) the public interest served by expeditious disclosure. G. L. c. 66, § 10(c). If the Supervisor determines that the request is part of a series of contemporaneous requests that are frivolous or designed to intimidate or harass, and the requests are not intended for the broad dissemination of information to the public about actual or alleged government activity, the Supervisor may grant a longer extension or relieve the agency or municipality of its obligation to provide copies of the records sought. Id. The filing of a petition does not affect the requirement that a Records Access Officer (RAO) must provide an initial response to a requestor within ten business days after receipt of a request for public records. 950 C.M.R. 36.06(4)(b). Request for Additional Time to Produce Records In its petition, the City requests, “an extension of twenty-five additional business days.” In support of its request the City provides the following information:

Michael Manning SPR26/1342 Page 3 April 16, 2026 The City of Worcester has identified approximately 145 potentially responsive records and communications to Ms. Shea’s request and seeks an extension of time to produce non-exempt portions of these records. Subsequent to the clarification of Ms. Shea’s request on March 16, 2026, the City has received 1,175 additional public records requests. It is likely that a portion of these additional requests will require similar levels of collaboration between the Worcester Public Schools and the City’s Law Department to fulfill. Further, many of these requests will contain records that require review and redaction by the City’s Law Department prior to production to the requestor. The request that is the subject of this petition is particularly challenging to fulfill not only due to the number of responsive records but due to the scale of the review required to protect exempt information. The records that Ms. Shea seeks originated from the Worcester Public Schools, the City expects to review and make redactions pursuant to the Family Educational Rights and Privacy Act (FERPA) as it operates through Exemption (a) of the Public Records Law to protect personally identifiable information (PII) of Worcester Public Schools students. Further where these records sought concern interactions between interns/employees of the Worcester Public Schools and a supervisor/mentor, the City must review the responsive records for personnel information that is “useful in making employment decisions regarding an employee” as defined by the Massachusetts Supreme Judicial Court in Wakefield Teacher’s Ass’n v. Sch. Comm. of Wakefield and redact such information under Exemption (c) of the Public Records Law. Such redactions may include but are not limited work evaluations of the employees identified by Ms. Shea’s request. In light of the need to collect and examine the records, and the capacity of the City to produce the records without an extension, the City has established good cause to permit an extension of time. G. L. c. 66, § 10(c)(i)-(iii). The City is granted an extension of 25 business days. Conclusion Accordingly, I find that the City has established good cause for a time extension of 25 business days as described above. Please note, Ms. Shea has the right to seek judicial review of this decision by commencing a civil action in the appropriate superior court. See G. L. c. 66, §§ 10(c), 10(d)(iv)(4), 10A(c).

Michael Manning SPR26/1342 Page 4 April 16, 2026 Sincerely, Manza Arthur Supervisor of Records cc: Sheila F. Shea