b. Mandatory or discretionary?

The proscriptions against disclosure of records and information identified in §§ 10-616 and 10-617 are mandatory. The proscriptions contained in §§ 10-618 and 10-619 are discretionary. The Maryland Court of Appeals has addressed the interplay between the PIA's mandatory and discretionary provisions. Attorney Gen'l v. Gallagher, 359 Md. 341, 753 A.2d 1036 (2000). In Gallagher, the court rejected Gallagher's argument that his status as the party in interest allowed him to compel disclosure of records under § 10-618 that were otherwise subject to the mandatory nondisclosure provisions of §§ 10-615 to 10-617. 359 Md. at 355, 753 A.2d at 1044. Instead, the court held, if any exemption under §§ 10-615, 10-616, or 10-617 is applicable to a particular record, then it must be withheld. Id.