Recent Development: Immanuel v. Comptroller of Maryland: The Maryland Public Information Act's Financial Information Exemption and the Uniform Disposition of Abandoned Property Act's Publication Provision Do Not Allow For Disclosure of Information Beyond What is Explicitly Permitted

Authors

Jason C. Parkins

Abstract

The Court of Appeals of Maryland held that information beyond the scope required under the Uniform Disposition of the Abandoned Property Act's publication provision cannot be disclosed in response to a request for information made under the Maryland Public Information Act. Immanuel v. Comptroller of Maryland, 449 Md. 76, 97-98, 141 A.3d 181, 194 (2016). The court also held that the information required to bze published under the Abandoned Property Act may not be ordered by value, because such ordering would reveal personal financial information. Id. at 97, 141 A.3d at 194. Lastly, the court held that the intermediate appellate court properly required petitioner to modify his request to be consistent with the Maryland Public Information Act's financial information exemption. Id.

On November 3, 2011, Henry Immanuel ("Immanuel") submitted a request for information held by the Comptroller of Maryland ("Comptroller"). The request sought the names and addresses of individuals who held the 5,000 largest unclaimed abandoned property accounts, ordered by value. The Comptroller denied Immanuel's request, and determined that the information fell under the Maryland Public Information Act's ("MPIA") financial information exemption.

Recommended Citation

Parkins, Jason C. (2017) "Recent Development: Immanuel v. Comptroller of Maryland: The Maryland Public Information Act's Financial Information Exemption and the Uniform Disposition of Abandoned Property Act's Publication Provision Do Not Allow For Disclosure of Information Beyond What is Explicitly Permitted," University of Baltimore Law Forum: Vol. 47: No. 2, Article 8.
Available at: https://scholarworks.law.ubalt.edu/lf/vol47/iss2/8