Does Little Rock have to release a list of every city employee's name, salary, job title, and full/part-time status if a citizen asks for it?

Short answer Yes. Basic public employment information (name, salary, job title, department, full/part-time status, hours) is a personnel record and is open to inspection under FOIA. The AG had said this many times before.
State
Arkansas
Opinion
Opinion No. 2019-0073
Issued
December 13, 2019
Issued by
Office of the Arkansas Attorney General
Requested by
Matlock, Joy E Esq.

Apply this to your situation

This page answers the general question as of 2019. Ask about yours and see what current Arkansas law means for your facts, with citations you can check.

Disclaimer: This is an official Arkansas Attorney General opinion. AG opinions are persuasive authority but not binding precedent. This summary is for informational purposes only and is not legal advice. Consult a licensed Arkansas attorney for advice on your specific situation.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official AG opinion. The original opinion (linked on this page) is the authoritative source for any reliance.

Plain-English summary

Joy Matlock, director of marketing at the Little Rock Zoo, was the named subject of a FOIA request that the City of Little Rock had received. The request sought, for all current city employees, "name, annual salary, job title, department, part-time/full-time status, and (if part-time) number of hours worked in 2019." Ms. Matlock did not object to release; she just asked the AG to confirm the custodian's decision was correct.

The AG confirmed it. Basic public employment information of the kind requested is a personnel record under the FOIA, and the opinion says the office had reached that conclusion numerous times. It says the information is open to inspection and copying under FOIA.

Matlock did not object to release; she asked whether the custodian's decision was correct. The AG answered that it was consistent with FOIA and said her office had addressed this type of information many times before.

For a custodian handling the kind of employee list described in the request, the opinion supports releasing the listed fields: name, annual salary, job title, department, part-time/full-time status, and part-time hours worked in 2019.

Currency note

This opinion was issued in 2019. Subsequent statutory amendments, court decisions, or later AG opinions may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.

Common questions

Q: Did the AG approve release of information about all current city employees?
A: Yes. The custodian planned to release the requested fields for each current City of Little Rock employee, and the AG found that decision consistent with FOIA. The opinion does not discuss other categories of employees or records.

Q: Does the opinion require the city to create a new spreadsheet?
A: It does not decide that question. The opinion describes the information requested and the custodian's decision to release it; it does not address the format of the underlying record or whether a new one must be created.

Q: Does the opinion distinguish managers from other city employees?
A: No. The request covered current City employees, and the AG described the listed fields as basic public employment information. She did not draw a distinction by job level.

Q: Does the opinion cover volunteers or contractors?
A: The request and the AG's answer concerned current City employees. This opinion gives no answer about volunteers or contractors.

Q: Does the opinion set a deadline for the city to release the information?
A: No. It decides that the custodian's release decision is consistent with FOIA and does not discuss a release deadline.

Background and statutory framework

The opinion does not restate the FOIA framework. It says the office has consistently classified this basic public employment information as an employee's personnel record and treated it as open to inspection and copying under FOIA. The requested categories were name, salary, job title, department, part-time/full-time status, and, for part-time employees, hours worked in 2019.

Citations

  • Ark. Code Ann. § 25-19-105(c)(3)(B)(i) (AG review)

Source

Original opinion text

Opinion No. 2019-073
December 13, 2019

Joy E. Matlock, J.D., Director
Marketing & Development Office
Little Rock Zoo
1 Zoo Drive
Little Rock, AR 72205

Dear Ms. Matlock:

You have requested my opinion regarding the Arkansas Freedom of Information Act ("FOIA"). Your request, which is made as the subject, is based on Ark. Code Ann. § 25-19-105(c)(3)(B)(i) (Supp. 2017). This subdivision authorizes the custodian, requester, or the subject of certain employee-related records to seek an opinion from this office stating whether the custodian's decision regarding the release of such records is consistent with the FOIA.

Your correspondence indicates that the City of Little Rock has received a request under the FOIA for information on current City employees. In response to the request, the custodian intends to release each employee's "name, annual salary, job title, department, part-time/full-time status, and (if part-time) number of hours worked in 2019." You do not state any objection to the release of the information, but merely inquire if the custodian's decision is correct. It is my opinion that the custodian's decision to release the requested information is consistent with the FOIA.

This office over the years has addressed this type of information numerous times and has consistently concluded that this basic public employment information is properly classified as an employee's personnel record and that it is open to inspection and copying under the FOIA. I need not restate here the legal analysis that compels that conclusion. It is sufficient to state that the analysis remains unchanged since the issuance of those opinions cited above.

Therefore, the custodian's decision to release the requested information is consistent with the provisions of the FOIA.

Sincerely,

LESLIE RUTLEDGE
Attorney General

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