FC: FIRE replies to Politech post on Univ of NC flap, open-records law

From: Declan McCullagh (declanat_private)
Date: Thu Jan 10 2002 - 18:37:36 PST

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    FIRE is replying to this Politech message:
    
    "More on Univ. of NC, private email, and a twist on open records"
    http://www.politechbot.com/p-02958.html
    
    ---
    
    Previous ones in the thread:
    
    "Univ of NC student's father replies to Politech: 'abusive and libelous'"
    http://www.politechbot.com/p-02961.html
    
    "Did Univ. of NC at Wilmington divulge a professor's private email?"
    http://www.politechbot.com/p-02957.html
    
    
    -----Original Message-----
    From: Harvey Silverglate [mailto:hasat_private]
    Sent: Thursday, January 10, 2002 5:11 PM
    To: declanat_private
    Cc: david_smithat_private; Greg Lukianoff; Thor Halvorssen
    Subject: FW: FIRE's response concerning the NC Public Records Law
    
    
    Hey Declan,
    	FIRE has finally composed its response to the allegation that we took
    advantage of the supposed "ignorance" of our readers and tried to pull a
    fast one by failing to admit that the administration of the University of
    North Carolina-Wilmington was legally obligated to investigate the e-mails
    of
    Prof. Mike Adams, and then turn over logs to student Rosa Fuller, in the
    aftermath of Ms. Fuller's complaint that he'd libelled etc her. (In the
    first place, it's kind of absurd to think one would find an ignorant,
    gullible audience on your list-serve, of all places!)
    	The response, done by FIRE's Director of Legal and Public Advocacy Greg
    Lukianof, with input from me (as FIRE's co-founder and co-director and
    vice-president), is below. Greg may have sent it to you separately, but here
    it is again, just in case.
    	Would you please post it to the list-serve. Is there anything else that
    needs to be done in order to put this to rest? (I hate letting unfair, not
    to mention occasionally scurrilous accusations, go unanswered, as you know.)
    	Happy New Year, fella. To all of us in 2002, and to liberty!
    
    											Harvey Silverglate
    											hasat_private
    
    P.S.  In fairness, I'm copying FIRE's accuser (and, thus, my accuser as
    well), David Smith.
    
    							H
    
    ----------------------------------------------------------------------------
    ----------------
    
    Shortly before the New Year, David Smith (david_smithat_private)
    accused The Foundation for Individual Rights in Education (FIRE;
    www.thefire.org) of "depending on the ignorance of … readers" in seeking to
    foist on them, and on the public, FIRE's belief "that privacy laws trump
    state open records policy" in North Carolina. This concerned the row at the
    University of North Carolina at Wilmington involving student Rosa Fuller's
    accusations against Prof. Mike Adams, and Fuller's demand that she be
    provided with copies of Adams's e-mail traffic. Shortly after this, FIRE
    closed for its annual holiday break, explaining this belated response to
    this serious ­ and false ­ accusation. I'm responding, as FIRE's Director of
    Legal and Public Advocacy.
    
    We at FIRE spelled out our position in our first letter and in subsequent
    releases. While FIRE believes that Adams's communications simply do not fall
    under the North Carolina Public Records Act, we did not base our argument on
    privacy law, but rather on the threat to academic freedom and free speech at
    this public university that would recur if, every time a professor disagreed
    with a student, that student would be allowed to read all of that
    professor's e-mails or even e-mail logs. Consider how this would chill
    professor's speech and kill robust debate.
    
    As we said in our prior correspondence, Rosa Fuller was trying to punish or
    chill Prof. Adams's protected political speech by making charges of
    "defamation", "false representation", and "intimidation" for his response to
    her letter (I'd be happy to send anyone a copy of his response, which is
    shockingly mild in light of these accusations). His response to her letter
    was utterly outside the definitions of defamation, false representation, and
    threats and within the core protections of political speech of the First
    Amendment. That such clearly protected speech by a professor was being
    legally assaulted indicated that the student's exercise was one of
    intimidation and retribution, not of seeking legitimate redress. The student
    actually made threats that she would bring a lawsuit: "If it is found that
    Adams sent his false representation of me to others, inside or outside the
    University community, and if these others acted on his false representation,
    and sent me abusive e-mail messages, then I also shall accuse him of libel."
    FIRE believes that it was the university's moral and legal obligation to
    protect academic freedom in this clear instance of attempted intimidation.
    
    Although a lawsuit would be frivolous in our view, she did pursue claims of
    sexual harassment against one of her critics and claims of libel against
    Professor Adams through the university system. An excerpt from her October
    29, 2001 complaint says "I, therefore, accuse Mike Adams of libel in
    violation of the University's Computing Resource Use Policy. I ask the
    University to investigate my allegation and, if warranted, hold Adams
    accountable for his conduct under all applicable University policies and
    procedures. Rosa Turrisi Fuller." This e-mail complaint was filed only after
    she received the list of e-mails Adams had sent. It proves that not only did
    she intend to use the University's help to punish Adam's protected speech,
    but that she actually followed through on her threats once the University
    granted her request.
    
    As for our stance on the North Carolina Public Records Law (132-1), our
    position is that it was far from clear that it could be applied to what
    Fuller was looking for, in light of the serious privacy, free speech and
    academic freedom countervailing concerns. Consequently, UNCW should have
    resisted in deference to its moral and legal duty to protect privacy, free
    speech and academic freedom.
    The North Carolina Public Records Law applies only to "documents…made or
    received according to law or ordinance in connection with the transaction of
    public business by any agency of North Carolina government or its
    subdivisions." What constitutes a public record, by this definition, is by
    no means clear in the case law pertaining to the university setting. Rosa
    Fuller was looking to discover whom Adam's forwarded his response to ("I
    have reason to believe Adams may have sent copies of his false
    representation of me to others, inside and outside the University
    community"). Who Adams chose to share his personal opinions with is not a
    matter of "public business" by any but the most dangerously overbroad
    definition of "public business." By this definition, there would be
    virtually no such thing as a confidential message on a college campus,
    outside the few exceptions (which, incidentally, were far from exhaustive)
    listed in the Public Records Law. None of us would want to be on such a
    campus, I suspect.
    
    The definition of public records is limited to matters "in transaction of
    public business," which, in FIRE's view, exempts Adams's private e-mails to
    his friends and family that were disclosed to Rosa Fuller by Hal White.
    There is no need to seek specific exceptions, as these e-mails did not fit
    within the scope of the law. There is no case law in North Carolina to
    contradict our interpretation of "public records," and it is certain that
    everyone on the UNCW staff, with few exceptions, understood this distinction
    between public and private records. While in some instances the line might
    be difficult to draw, in the case of Professor Adams's e-mail, which the
    unfortunately released records show were sent to friends and family, it is
    clear they were personal.
    
    There is a commonly known and accepted zone of private communication that is
    explicitly recognized and respected at many universities (to see the schools
    that do, please visit the Electronic Frontier Foundation's website at
    www.eff.org/CAF/faq/email.policies). Almost all colleges recognize a student
    's and a professor's right to privacy through usage, custom or other less
    formal approaches. The fact that the UNCW Computing Policy states that users
    should have "no expectation of privacy" is irrelevant, as that is
    contradicted by other stated policies and other practices of UNCW.  Further,
    this policy was likely propagated by the computing resource center without
    the required process to make it an actual rule at a public university. (For
    anyone who doesn't understand the limited power of these sorts of rules,
    please read Carl Kadie's critique of UNCW's policy at
    www.eff.org/CAF/policies/uncwil-edu.htm. FIRE agrees with Carl's stance on
    these issues.)
    
    UNCW was not at all confident that the Public Records Law applied to Adams's
    e-mail. Indeed, the university's strongest statement that these records may
    have been covered by the Public Records Law was in the faculty minutes for
    November, which only stated: "It is possible that a court could find that
    all documents, emails, etc. produced at work or on stored on university
    property are public records. " (www.uncwil.edu/facsen/minutes/Nov01.htm)
    Since UNCW had constitutional, federal, state and ethical concerns that
    argued against going into Adams's private e-mails in this situation, it
    should not have acted unless the duty to do so was clearer than this.
    
    Interestingly, there was almost no risk for UNCW if it had taken a
    principled stand to protect privacy, free speech, and academic freedom in
    this case. There are procedures in the Public Records Law to deal with a
    situation like this. Under 132-9, Fuller would be allowed to get an
    immediate hearing with the General Court of Justice to compel the e-mail's
    release. FIRE deems it unlikely that the case would have been pushed this
    far, and even more unlikely that her request would be granted. Even if the
    University were to lose, the only sanction allowed against UNCW would be
    attorney's fees, which would be the small cost of filing an open records
    claim. But even this minor penalty seems unlikely as, under 132-9(c)(1),
    attorney's fees will not be awarded if the party refusing had "substantial
    justification." Privacy interests, academic freedom and the First Amendment
    are "compelling interests, " providing far more than the required
    "substantial justification."
    
     >From the record, virtually everyone at UNCW knew the problems ­ moral and
    legal—of this invasion of privacy, from the lab techs, to the faculty, to
    the General Counsel who carried out the orders. UNCW was aware of the threat
    to academic freedom and free speech this case represented. They had no clear
    basis for believing that the Public Records Law even applied to what was
    being demanded, and they risked little (and potentially had much to gain) if
    they had chosen to defend, rather than to sacrifice, these personal rights
    and institutional interests. Under these circumstances, FIRE remains
    appalled that UNCW capitulated.
    
    The day that liberty is deemed a more important interest warranting
    protection by a university, rather than avoidance of any theoretical
    liability regardless how remote, is the day FIRE shall consider its mission
    largely accomplished. Until then, we will be vigilant.
    
    	Greg Lukianoff
    	Director of Legal and Public Advocacy, FIRE
    	gregat_private
    
    
    
    
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