disclosure rule (Vermont) · Go Syfert
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disclosure rule in Vermont

7 Vermont opinions name it 2 courts 1992–2025 1 in the last five years

The cases below were cited by Vermont courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
cluster 1741green
· · cited in 1 Vermont opinions naming this issue, 2013–2013
1 sentence

2013The substantial governmental interest involved is *643 in “providing the electorate with information about the sources of election-related spending.” Citizens United, 558 U.S. at 367 (quotation omitted).

11
Center for Individual Freedom v. Madigangreen
ca7 · 2012 · cited in 1 Vermont opinions naming this issue, 2013–2013
1 sentence

2013Thus, these requirements must meet a standard of exacting scrutiny, “which requires a substantial relation between the disclosure requirement and a sufficiently important governmental interest.” Id. at 366-67 (quotation omitted); see Madigan, 697 F.3d at 477 .

11
Young v. Ricegreen
ark · 1992 · cited in 1 Vermont opinions naming this issue, 2003–2003
1 sentence

2003In defining the exception, the Court looked to the intent of the legislature and construed the term in a limited way “to apply only when the privacy of the individual is involved.....Thus, it covers personal documents only if they reveal ‘intimate details of a person’s life, including any information that might subject the person to embarrassment, harassment, disgrace, or loss of employment or friends.’” Id. at 110 [citing Young v. Rice, 826 S.W.2d 252, 255 (Ark. 1992)].

11
Mans v. Lebanon School Boardgreen
nh · 1972 · cited in 1 Vermont opinions naming this issue, 1993–1993
1 sentence

1993See Department of Air Force v. Rose, 425 U.S. 352, 370-82 (1976) (interpreting Exemption 6 of the Freedom of Information Act, 5 U.S.C. § 552 (b)(6)); Mans v. Lebanon School Board, 290 A.2d 866, 868 (N.H. 1972) (personnel files exemption limited to instances where disclosure would constitute invasion of privacy).

11
Department of the Air Force v. Rosegreen
scotus · 1976 · cited in 1 Vermont opinions naming this issue, 1993–1993
1 sentence

1993See Department of Air Force v. Rose, 425 U.S. 352, 370-82 (1976) (interpreting Exemption 6 of the Freedom of Information Act, 5 U.S.C. § 552 (b)(6)); Mans v. Lebanon School Board, 290 A.2d 866, 868 (N.H. 1972) (personnel files exemption limited to instances where disclosure would constitute invasion of privacy).

11
In Re FEFgreen
vt · 1991 · cited in 1 Vermont opinions naming this issue, 1992–1992
1 sentence

1992In In re F.E.F., 156 Vt. 503, 510 , 594 A.2d 897, 902 (1991), we explored in detail the purpose of the reporting prong of Rule 16(c). 3 That discussion is instructive here: The Reporter’s Notes and drafting source shed some light on the meaning of this prong.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Vermont. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Trombley v. Bellows Falls Union High School District No. 27 green
vt · 1993
2 sentences

2025Interpreting the term this broadly “would consume the disclosure rule.” Id.

2003The Vermont Supreme Court rejected the argument that this term includes “any document about specific people” because such definition would “consume the disclosure rule.” Id.

32003–2025
Kade v. Smith green
vt · 2006
2 sentences

2012Unlike the cases on which plaintiffs rely, the language used in § 317(c)(24) is not “vague and potentially limitless.” See, e.g., Kade v. Smith, 2006 VT 44, ¶ 8 , 180 Vt. 554 , 904 A.2d 1080 (mem.) (finding terms of “personal documents” exemption under PRA to be “vague and potentially limitless,” and reasoning that because a broad construction of the term would consume the disclosure rule, exemption must be limited to instances where disclosure would constitute an invasion of personal privacy).

2012Unlike the cases on which plaintiffs rely, the language used in § 317(c)(24) is not “vague and potentially limitless.” See, e.g., Kade v. Smith, 2006 VT 44, ¶ 8 , 180 Vt. 554 , 904 A.2d 1080 (mem.) (finding terms of “personal documents” exemption under PRA to be “vague and potentially limitless,” and reasoning that because a broad construction of the term would consume the disclosure rule, exemption must be limited to instances where disclosure would constitute an invasion of personal privacy).

12012–2012
F.E.F. v. Cameron green
vt · 1991
1 sentence

1992In In re F.E.F., 156 Vt. 503, 510 , 594 A.2d 897, 902 (1991), we explored in detail the purpose of the reporting prong of Rule 16(c). 3 That discussion is instructive here: The Reporter’s Notes and drafting source shed some light on the meaning of this prong.

11992–1992

Statutes the citing opinions construe

USC § 5u.s.c.552 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 120 (1960–2025) DE 74 (1980–2025) IL 58 (1955–2026) AZ 47 (1974–2026) NY 43 (1963–2026) TX 41 (1992–2025) PA 35 (1971–2026) MD 35 (1949–2022) CT 29 (1940–2021) NJ 29 (1971–2024) MA 26 (1975–2025) OH 26 (1989–2026) FL 20 (1974–2016) WA 20 (1992–2026) MI 18 (1928–2023) OR 16 (1984–2022) ND 15 (1981–2012) MO 14 (1975–2025) NM 13 (1986–2024) AR 11 (1988–2026) VA 11 (2004–2024) TN 10 (1992–2025) IN 10 (1978–2020) WI 10 (1980–2023) ID 10 (2002–2025) IA 9 (1988–2020) ME 9 (2001–2017) MS 9 (1989–2021) MN 8 (1976–2006) KS 8 (1973–2026) UT 8 (1989–2026) NC 8 (1986–2015) CO 7 (1985–2020) NV 7 (2012–2022) VT 7 (1992–2025) WV 6 (1914–2021) AL 6 (1973–2015) LA 5 (1989–2013) KY 5 (1995–2026) DC 5 (1980–2023) HI 5 (1995–2021) WY 4 (1988–2017) OK 4 (1983–2008) SC 3 (2006–2013) AK 3 (1996–2026) NE 3 (1981–1997) GA 2 (1981–1984) MT 2 (1997–2002) NH 2 (1995–2010)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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