PUBLIC RECORDS - SOUTH CAROLINA

DomainsNewMedia.com, LLC v. Hilton Head Island-Bluffton Chamber of Commerce

Supreme Court of South Carolina - May 23, 2018 - S.E.2d - 2018 WL 2325622

Records requester brought action against chamber of commerce, seeking injunctive relief and declaration that chamber was subject to the state Freedom of Information Act (FOIA).

The Circuit CourT granted requester’s motion for summary judgment. Chamber appealed.

The Supreme Court of South Carolina held that chamber was not a “public body,” and thus was not subject to FOIA.

Chamber of commerce was not a “public body,” and thus was not subject to state Freedom of Information Act (FOIA) disclosure requirements; even though chamber received and expended accommodation tax funds as designated marketing organization for local government and received grant from department of parks, recreation, and tourism, FOIA was general law, and specific tax statute and proviso provided different accountability measures and public access to information regarding how funds were spent.



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