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PR 18-16 Boynton v. Rhode Island Interscholastic League No Violation

The Complainant alleged that the RIIL failed to respond to his requests for documents. The RIIL maintained that they are not a "public body" under the APRA. In determining whether the RIIL is a "public body" pursuant to the APRA, we found that the RIIL is not "acting on behalf of and/or in place of" a governmental entity. R.I. Gen. Laws 38-2-2(1). Indeed, no evidence was presented that any school committee has expressly delegated any services to the RIIL. Instead, the evidence demonstrated that, as a 501(c)(3) nonprofit corporation, the RIIL elects its own members and maintains control of its finances. As membership is voluntarily determined by a school's principal, including private schools, the RIIL operates completely independent from any school committee. These facts are corroborated by the Rhode Island Supreme Court's decision in Hebert v. Ventetuolo, 480 A.2d 403, 407 (R.I. 1984). Therefore, we found that the RIIL was not a "public body" under the APRA, and, accordingly, found no violations.

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