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Keywords

statuteappealtrial
statuteappealtrialappellee

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Waggoner v. State, 666 S.W.3d 384

Facts

Kevin Lee Waggoner filed an action in the Chancery Court for Davidson County seeking access to audio recordings from his murder trial held in Union County. The trial court ruled that the clerk of the criminal court was not required to store the recordings and that they were exempt from disclosure under Tennessee Supreme Court Rule 34. Waggoner argued that the recordings were public records and that he had made proper requests for them, which the court denied.

Petitioner sought the audio recordings from his criminal trial held several years earlier in Union County. The trial court held that the clerk of the criminal court in which Petitioner's trial was held was not required by statute to store the recordings as part of the clerk's case records.

Issue

Whether the trial court correctly concluded that the audio recordings from Waggoner's trial were not required to be maintained by the court clerk and were exempt from disclosure under the Tennessee Public Records Act.

Whether the trial court correctly concluded that Tennessee Code Annotated section 40-14-307 does not require the verbatim recording used by a court reporter in generating a written transcript to be filed and maintained by the criminal court clerk as part of the court's records.

Rule

Tennessee Code Annotated section 40-14-307 requires that verbatim recordings made by court reporters be filed and maintained by the court clerk as part of the trial records.

Tennessee Code Annotated section 40-14-307 requires the court clerk to preserve as a part of the trial court records the 'records' of court proceedings that have been certified by a 'designated court reporter.'

Analysis

The Court of Appeals analyzed the statutory requirements under Tennessee Code Annotated section 40-14-307, concluding that the trial court erred in its interpretation. The court found that the statute mandates that any verbatim recordings made during a trial must be filed with the court clerk, and thus, the audio recordings in question were public records that should not have been exempt from disclosure.

The trial court determined, and Appellees now argue on appeal, that the statute requires only that the court clerk maintain a copy of the written transcript inasmuch as the transcript is the 'official record' of the trial.

Conclusion

The Court of Appeals reversed the trial court's decision and remanded the case for further proceedings, ruling that the audio recordings were public records and not exempt from disclosure.

We reverse the trial court's decision as to both issues and remand for further proceedings.

Who won?

Kevin Lee Waggoner prevailed in the case because the Court of Appeals found that the audio recordings were public records that should be disclosed under the Tennessee Public Records Act.

The Court of Appeals, Davis, J., held that: 1 when a court reporter utilizes audio recording devices or stenography to make verbatim recordings, the reporter must file resulting recordings or stenographic notes with the court clerk; 2 audio recordings from murder trial were public records for purposes of Public Records Act; and 3 audio recordings from murder trial were not exempt from disclosure.

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