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Virginia FOIA Inapplicable to State Corporation Commission
On May 13, 2009, George H. Christian requested that the SCC produce documents pursuant to the VFOIA. On May 22, 2009, Deputy General Counsel Philip R. de Haas responded that the VFOIA does not apply to the SCC and claimed that the information Christian requested was not available.
On June 22, 2009, Christian again requested that SCC provide the requested documents. On July 9, 2009, a single document responsive to Christian's request was provided and the SCC dismissed the action on November 5, 2010.
Christian appealed, raising 17 assignments of error. The Virginia Supreme Court affirmed, however, concluding that the "VFOIA . . . is functionally unenforceable against the SCC." Hence, the Court found "the VFOIA inapplicable to the SCC. This substantive determination resolves or renders moot all of Christian's assignments of error." See: Christian v. State Corporation Commission, 282 Va. 392, 718 S.E.2d 767 (2011).
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Related legal case
Christian v. State Corporation Commission
|Cite||282 Va. 392, 718 S.E.2d 767 (2011)|
|Level||State Supreme Court|