PUBLIC RECORDS - KANSAS

State v. Great Plains of Kiowa County, Inc.

Court of Appeals of Kansas - February 10, 2017 - 389 P.3d 984

County filed petition against non-profit hospital administrator, seeking to enforce Kansas Open Records Act. Both parties moved for summary judgment.

The District Court entered judgment in favor of county. Administrator appealed.

The Court of Appeals held that non-profit hospital administrator’s financial records relating to hospital it leased from county board of trustees of hospital fell within statutory definition of public records.

Non-profit hospital administrator’s financial records relating to hospital it leased from county board of trustees of hospital fell within statutory definition of “public records” under Kansas Open Records Act. Board was statutorily required to maintain the financial records of the hospital, and, as a result of the lease and fact that board failed to maintain such records, administrator was the custodian of the public financial records.



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