Penncrest SD v. Cagle, T., Aplt.

Summary

The Court affirmed the Commonwealth Court’s decision to remand the RTKL dispute for further factfinding concerning whether Facebook posts on school-board members’ personal accounts were agency records. It held that the RTKL contains one two-part inquiry applicable to all forms of information: whether the information documents an agency transaction or activity and whether it was created, received, or retained pursuant to law or in connection with agency business. The Court rejected a separate social-media-specific test but approved consideration of context-specific facts, including the account’s characteristics, the post’s content, and the official’s capacity. Separate opinions were filed, but their reasoning is not included in the supplied text.