Pallotto v. Pennsylvania State University Police and Public Safety

Case Number: 2025-CV-2635-CI

Court: Centre County Court of Common Pleas

Clients: Bret Pallotto and The Centre Daily Times

Background: In June 2025, Centre Daily Times reporter Bret Pallotto filed a request under Pennsylvania’s Right-to-Know Law seeking payroll records, including overtime pay, for all Pennsylvania State University Police and Public Safety officers in 2024.

Penn State denied the request, claiming the police department is a unit of the university, which is exempt from the definition of “agency” under the RTKL. Pallotto and The Centre Daily Times appealed to the Pennsylvania Office of Open Records. The OOR sided with the university.

On behalf of Pallotto and The Centre Daily Times, Paula Knudsen Burke, the Reporters Committee’s Pennsylvania-based attorney, filed this appeal of the OOR’s determination. The appeal argues that the Penn State police department is an agency subject to the RTKL because there is government control over its operations, it serves a government function, and the government exercises significant control over public money it assigns to the department. 

The court scheduled a hearing in the case for May 29, 2026.

Quote: “The Department’s connection to a state-related institution does not isolate it from scrutiny under the RTKL,” the petition for review states. “… The Department is not a private police force formed to enforce rules unique to the University campus; it is a government police force with the same law enforcement powers as other police agencies in the state.”

Related: Burke is representing independent journalist Henry Bard in a companion case against the University of Pittsburgh Police Department that also seeks to establish that university police forces are subject to the RTKL.  

Filings:

2025-08-25: OOR final determination

2025-09-24: Requester petition for review

2026-03-10: Scheduling order