Troutt Brothers, Inc. v. Emison

Two 16-year-old girls and one 15-year-old girl were arrested on charges related to the stabbing and murder of an individual in Mississippi County, Arkansas. Following their arrest, all three girls were transported to a regional juvenile detention center. Under Arkansas law, the two 16-year-olds were eligible to be charged as either adults or juveniles. However, during the relevant time period, none of the girls had been formally charged as juveniles nor had any formal juvenile proceedings commenced. While at the juvenile facility, the three girls attacked a prison matron and escaped. A newspaper employee from the Jonesboro Sun heard the police broadcasts documenting the escape and went to the facility to ask what happened and filed a request pursuant to the state’s open-records law. The deputy sheriff refused to release the names of the girls, stating that he was prohibited by law from releasing the names of juveniles under the state’s juvenile code, which prohibited the release of the names and identities of the subjects of juvenile proceedings except by court order. Troutt Brothers, Inc. (plaintiff), the parent company of the Jonesboro Sun, filed suit against the sheriff, Larry Emison (defendant), in circuit court seeking the release of the names. Emison asserted that federal law prohibited the disclosure of certain juvenile records and that because Arkansas participated in a federal grant program and might lose money if it did not comply with the program’s requirements, this should be imputed as part of the state’s open-records law. The circuit court found that the state legislature did not word the statute as intended and therefore found that Emison did not violate the open-records law by withholding the records. Troutt Brothers filed an appeal.