In the matter of Frank Curry and Foiabuddy, OOR Docket No.: AP 2024-1311 (June 20, 2024), the OOR determined that the South Western School District did not have a duty to fulfill an online request seeking IT related information because the district could not confirm the requester was qualified. A “requester” is defined by the RTKL as “[a] person that is a legal resident of the United States….” See 65 P.S. § 67.102. Thus, under the RTKL, a requester must both be a “person” and “a legal resident of the United States.” The district submitted evidence that it could not determine whether the Requester was, in fact, “Frank Curry”, a resident of the United States or his contact information because the Requester had used FOIABuddy’s anonymous on-line request function. Because the District had submitted evidence tending to show that the Request was an anonymous request, the OOR determined that the district had met its burden of proof that the Request was anonymous and it was not required to respond.
