Requirement of Non-Mailing Assurances for Public Records Lists Under Idaho Law: Sentry Dynamics, Inc. v. Ada County

Introduction

The Idaho Supreme Court decision in Sentry Dynamics, Inc. v. Ada County establishes that, when a public records requester seeks a compiled “list of persons” (e.g., owner names and addresses), a public agency may condition release upon an assurance that the records will not be used as a mailing or telephone list by the requester or its downstream recipients. This commentary reviews the facts, the issues presented, the court’s ruling, and its implications for Idaho’s Public Records Act.

Background: Sentry Dynamics, a property‐data provider, requested Ada County assessor data (GIS and CAMA records including owner names and addresses). Believing Sentry intended to resell mailing lists, the County denied the request under Idaho Code § 74-120(1). Sentry sued in district court; the County denied jurisdictional sufficiency and sought to enforce an “Acknowledgment and Agreement” requiring broad non-use covenants. After cross motions, the district court granted access but struck certain Agreement provisions and ordered the County to supply an electronic copy in its chosen format. Ada County appealed; Sentry cross-appealed on format.

Summary of the Judgment

The Supreme Court of Idaho, in an opinion by Justice Moeller, held:

The district court had jurisdiction despite Sentry’s captioning of its filing as a “complaint” rather than a “petition” under Idaho Code § 74-115.
Sentry’s request for “owner names and addresses” constituted a “list of persons” under § 74-120(1)(a)–(b), triggering the mailing-list exception.
Under § 74-120 and § 74-102(5)(b), Ada County may require Sentry to assure that neither it nor its clients will use the records as a mailing or telephone list. Sentry’s refusal to provide that assurance relieved the County of any obligation to distribute a compiled list.
The district court properly invalidated three overly broad Agreement provisions (website-terms changes, third-party distribution control, indemnification) as exceeding the “inquiry” authorized by § 74-102(5). Other less intrusive assurances were permissible.
No statutory provision compelled the County to furnish records in any particular electronic format; the order requiring an electronic production was reversed.

Analysis

Precedents Cited

The court relied on established authority for summary-judgment standards, statutory interpretation, and public-records jurisprudence:

Krinitt v. Idaho Dep’t of Fish & Game, 162 Idaho 425 (2017) – summary-judgment de novo review.
Robison v. Bateman-Hall, Inc., 139 Idaho 207 (2003) – no genuine dispute as to material fact standard.
Ward v. Portneuf Med. Ctr., 150 Idaho 501 (2011) – free review of statutory interpretation.
Cover v. Idaho Bd. of Corr., 167 Idaho 721 (2020) and Bolger v. Lance, 137 Idaho 792 (2002) – narrow construction of PRA exemptions and presumption of openness.

These authorities guided the court’s de novo review of statutory language and emphasized that exceptions to public‐records access be construed narrowly.

Legal Reasoning

Statutory Text: Idaho Code § 74-120(1)(a)–(b) prohibits agencies from distributing “lists of persons” for mailing or telephone-list use without consent of those listed. Section 74-102(5)(b) allows custodians to “inquire” to “ensure” the records will not be so used. Section 74-102(15) permits but does not require electronic delivery.

“List of Persons”: The requested owner names and addresses, compiled in GIS/CAMA files, plainly constitute a list. The court analogized that a dictionary remains a list of words despite additional data.

Inquiry vs. Conditions: The PRA forbids broad gatekeeping. A custodian may question a requester’s intended use, and require a truthful assurance against prohibited mailing-list use. Demands extending beyond that inquiry—such as altering website terms, restricting all redistributions, or indemnifying the County—exceed statutory authority and were invalidated.

Format of Delivery: Because the PRA confers no affirmative right to an electronic copy or any particular format, the court reversed the district court’s order compelling electronic production.

Impact

Public agencies in Idaho may condition release of compiled lists of names/address on a requester’s promise not to resell or otherwise facilitate mailing/telephone-list uses, including downstream use by clients.
Excessive contractual or indemnity requirements are invalid; agencies must confine themselves to a limited “inquiry” and assurance under § 74-102(5)(b).
Requesters remain free to examine and compile their own lists manually if they refuse to give the required assurance.
No entity is entitled to demand public records in a specific electronic format—even if the agency stores them electronically—unless expressly provided by statute or agreement.
The decision clarifies the balance between transparency and privacy concerns (e.g., preventing bulk mailing abuses) under Idaho’s Public Records Act.

Complex Concepts Simplified

Public Records Act (PRA): Idaho’s law (Title 74) that makes most government documents open to inspection, subject to narrow exemptions.
“List of Persons”: Any compilation of individual names (and associated data) that could be used to send mass mailings or telephone calls.
Inquiry vs. Condition: An “inquiry” is a simple question about intended use. A “condition” (e.g., changing website terms or indemnifying) goes beyond that question and is not allowed.
GIS and CAMA Data: Geographic Information System (GIS) files store parcel boundaries and coordinates; Computer Assisted Mass Appraisal (CAMA) files store valuation data. Combined with owner names and addresses, they form the County’s property database.
Shapefile: A database format (.dbf + .shp files) commonly used in mapping software to represent geographic features along with attribute data (like owner names).

Conclusion

The Supreme Court of Idaho in Sentry Dynamics, Inc. v. Ada County affirmed that when a requester seeks an agency’s compiled “list of persons” (such as owner names and addresses), the Public Records Act empowers the agency to request an assurance that the data will not be used as a mailing or telephone list by the requester or its downstream recipients. Agencies may not impose broader contractual burdens or indemnities, nor can requesters demand records in any specific electronic format. This ruling strikes a careful balance—maintaining open government data while protecting individuals from unwanted mass mailings or calls—and provides clear guidance for both agencies and requesters navigating Idaho’s public-records regime.