Warnick v. Court Administration of 1st Judicial District.
2025 COA 7. No. 24CA0576. Public Access to Information and Records Rule 2—Records in Related Proceeding—Denied Inspection of a Record—Petition to the District Court—Declaratory Relief.
January 16, 2025
Warnick requested hearing transcripts in a First Judicial District domestic relations case to which he was a party. Warnick received the transcripts but later submitted a request under Public Access to Information and Records Rule 2 (PAIRR 2) to the State Court Administrator’s Office (SCAO) for the dates the transcriber was provided the recordings of the hearings for which he had requested transcripts. SCAO redirected Warnick to the First Judicial District where Warnick forwarded his request, stating that he was trying to determine why the transcripts weren’t produced to him within 30 days. The records custodian, Stenstrom, responded the next day and told Warnick she was researching the issue. About a month later, having received no further response, Warnick filed a complaint under PAIRR 2 alleging that the First Judicial District, through Stenstrom, had willfully refused to respond to his records request. He sought an order requiring Stenstrom to show cause why she should not be required to permit the requested inspection. Over the next few months, the First Judicial District fulfilled Warnick’s multiple information requests. Ultimately, the First Judicial District filed its response to Warnick’s complaint and asked the district court to discharge the complaint because it was not withholding any records for inspection. The district court ruled that because the First Judicial District had indisputably provided all responsive records in its custody and control, Warnick did not have a cause of action, and it dismissed the complaint.
On appeal, Warnick contended that the district court erred by dismissing his complaint because he believes there may be other responsive documents that were not provided. However, it is undisputed that Warnick was not denied inspection of any record, and by the time of the court’s dismissal, the First Judicial District had responded repeatedly and provided Warnick all the responsive documents it had located. Because there is no factual dispute that Warnick was not denied inspection of any record, the district court correctly dismissed the complaint.
Warnick also argued that the district court erred by denying his motion to amend his complaint to add claims for declaratory judgment. To the extent he sought a declaratory judgment that the First Judicial District had violated PAIRR 2 in ways other than by denying him inspection of a record, PAIRR 2 provides no such cause of action, and Warnick otherwise cited no substantive law that does. To the extent Warnick sought declaratory judgments concerning when the audio recordings were delivered to the transcription firm and whether any delay was within his control, he also cited no legal basis for those claims. Thus, even assuming the district court erred by denying the motion to amend, any error was harmless because the proposed amendment did not state a valid legal basis for relief.
Warnick further asserted that the district court acted improperly and showed bias by considering information from his underlying domestic relations case. But the district court may consider court records in a related proceeding, and the facts Warnick asserts do not support an inference of actual bias.
The judgment was affirmed.