25FC:0175 Timothy Gray v. Woodbury Central Community School District - Investigative Report and Probable Cause Order

The Iowa Public Information Board

COMES NOW, Charlotte Miller, Executive Director for the Iowa Public Information Board (“IPIB”), and enters this Investigative Report:

On November 6, 2025, Timothy Gray filed formal complaint 25FC:0175, alleging Woodbury Central Community School District (“District”) violated Iowa Code chapter 22.

The IPIB accepted this Complaint on December 11, 2025

Facts

On October 2, 2025, Mr. Gray requested a copy of his educational file from the District. On the same date, the District provided the Complainant with a copy of the public record.

On November 6, 2025, the Complainant filed this complaint alleging that the District was improperly withholding responsive records.

On December 11, 2025, IPIB staff notified the District of the complaint. The same day, the Superintendent of the District spoke with IPIB staff on the phone and informed IPIB the steps taken to comply with Complainant’s public record request including an explanation of how the record was located and scanned by the custodian and, upon request, emailed to the Complainant. The District also had the custodian, the high school principal, confirm over the phone that those were actions taken.

Complainant alleged on December 11, 2025, that due to history of interactions with law enforcement, communication of guidance counselor with Complainant’s father, and the nature of being a child in need, that the District would have more records those produced.

The District has held that it has provided all responsive records in relation to Complainant to him.

Applicable Law

Chapter 22 grants every person the right to examine or request a copy of a public record. Iowa Code § 22.2(1). Public records are “all records, documents, tape, or other information, stored or preserved in any medium” by a government body. Iowa Code § 22.1(3).

Analysis

If a records custodian does not possess the records requested, the custodian may respond by stating that it has no records responsive to the request. Nothing in Chapter 22 requires a lawful custodian to create records that it does not possess. The facts show the District fulfilled its legal obligation under Chapter 22 when it responded to Complainant’s request.

IPIB Action

The Board may take the following actions upon receipt of a probable cause report:

a. Redirect the matter for further investigation;

b. Dismiss the matter for lack of probable cause to believe a violation has occurred;

c. Make a determination that probable cause exists to believe a violation has occurred, but, as an exercise of administrative discretion, dismiss the matter; or

d. Make a determination that probable cause exists to believe a violation has occurred, designate a prosecutor and direct the issuance of a statement of charges to initiate a contested case proceeding.

Iowa Admin. Code r. 497-2.2(4).

Recommendation

Because the District provided the requested records to Complainant, IPIB staff recommends that the Board dismiss the matter for lack of probable cause to believe a violation has occurred.

By the IPIB Executive Director:

_________________________

Charlotte J.M. Miller, J.D.

CERTIFICATE OF MAILING

This document was sent on January 9, 2026, to:

Timothy Gray, Complainant

Woodbury Central Community School District, Respondent

The Iowa Public Information Board

Under Iowa Admin. Code r. 497-2.2(4) the Board takes the following action:

☐a. Redirect the matter for further investigation;

☒b. Dismiss the matter for lack of probable cause to believe a violation has occurred;

☐c. Make a determination that probable cause exists to believe a violation has occurred, but, as an exercise of administrative discretion, dismiss the matter; or

☐d. Make a determination that probable cause exists to believe a violation has occurred, designate a prosecutor and direct the issuance of a statement of charges to initiate a contested case proceeding.

By the Board Chair

___________________________________

Catherine Lucas

CERTIFICATE OF MAILING

This document was sent on January 20, 2026, to:

Timothy Gray, Complainant

Woodbury Central Community School District, Respondent