Utah Court of Appeals
Must Utah counties provide electronic database copies under GRAMA? Maese v. Davis County Explained
Summary
Maese submitted a GRAMA request to Davis County seeking either a copy of the property transaction database in electronic format or a compiled transaction report for the past 20 years. Davis County declined to provide the database copy, instead informing Maese that the records were accessible through their Redi-Web system and at the Recorder’s Office. The trial court granted Davis County’s motion to dismiss Maese’s complaint for failure to state a claim.
Practice Areas & Topics
Analysis
Background and Facts
S. Steven Maese submitted a Government Records Access Management Act (GRAMA) request to Davis County seeking either a copy of the property transaction database in electronic format or a compiled transaction report covering the past 20 years. Davis County declined to provide the requested database copy, instead informing Maese that the records were accessible through their online Redi-Web system and at the Recorder’s Office. When Maese filed suit claiming GRAMA violations, Davis County moved to dismiss under Rule 12(b)(6) for failure to state a claim upon which relief can be granted.
Key Legal Issues
The primary issues were whether GRAMA required Davis County to provide an electronic copy of its entire property database, whether the county could satisfy GRAMA by providing access through existing systems, and whether the county was required to compile a transaction report. The court also addressed whether Maese’s assertions about the database containing unique metadata constituted factual allegations or legal conclusions.
Court’s Analysis and Holding
The Utah Court of Appeals affirmed the dismissal, holding that GRAMA was satisfied when Davis County made the requested records accessible in identical physical form and content through its Redi-Web system and informed Maese of such access. The court determined that Maese’s assertions about the database being a distinct public record due to metadata were legal conclusions rather than factual statements that the trial court was required to accept. Additionally, GRAMA expressly states that governmental entities are not required to compile, format, or manipulate information, relieving Davis County of any obligation to create a compiled transaction report.
Practice Implications
This decision clarifies that GRAMA’s access requirements can be satisfied through existing systems rather than requiring creation of new formats or compilations. Practitioners should carefully draft GRAMA requests to clearly describe the specific records sought, as broad assertions about database access or metadata may be deemed legal conclusions rather than factual allegations. The ruling also confirms that governmental entities may direct requesters to existing access points rather than providing customized electronic copies, provided the records are available in identical form and content.
Case Details
Case Name
Maese v. Davis County
Citation
2012 UT App 48
Court
Utah Court of Appeals
Case Number
No. 20100663-CA
Date Decided
February 24, 2012
Outcome
Affirmed
Holding
GRAMA does not require a governmental entity to provide an electronic copy of an entire database when the requested records are accessible in identical physical form and content through the entity’s online system and physical office.
Standard of Review
Correctness for questions of law including whether a trial court properly granted a rule 12(b)(6) motion to dismiss
Practice Tip
When challenging GRAMA compliance, ensure your client’s original request clearly describes the specific records sought rather than making broad assertions about database access or metadata that may constitute legal conclusions rather than factual allegations.
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