Smith v. Northside Hospital, Inc

Summary

The court held that a private corporation operating a public hospital under a broad lease and delegation of governmental authority may maintain public records even without the agency's specific knowledge, direction, or approval of each activity. Records concerning operation of the leased facilities are public records, while acquisition-related records require a fact-specific determination of their connection to that operation. The court reversed and remanded because the lower courts applied an overly narrow legal standard.