Complaint
Filed 2025-08-04 · By Joy Ramsingh (Ramsingh Legal) on behalf of Georgia Trust for Local News LLC d/b/a The Macon Melody · Document type Complaint with Exhibits A-F View the PDF →
What is this document?
This is the Complaint — the document that started the lawsuit. On August 4, 2025, Macon attorney Joy Ramsingh filed this pleading in Bibb County Superior Court on behalf of The Macon Melody, a nonprofit local news outlet operated by Georgia Trust for Local News LLC (d/b/a — “doing business as” — The Macon Melody). The Complaint asks a judge to order the Bibb County School District (“BCSD”) to hand over a single piece of information: the dollar amount of a settlement that the Bibb County Board of Education publicly voted to approve on July 18, 2024 for a student identified in the board’s own minutes as “Student JH” (the minor student at the center of the settlement).
Reporter Laura Corley had submitted an Open Records Act (ORA — Georgia’s state-law equivalent of a freedom-of-information request) request on June 2, 2025 asking only for “the dollar amounts of settlements the school board approved in 2024.” The District refused. Its written denial (attached as Exhibit B) claimed that turning over the dollar figure would reveal “confidential, personally-identifiable, education-related information” about a student, and invoked the federal Family Educational Rights and Privacy Act (“FERPA” — the federal law protecting student education records).
The Complaint frames that denial as unlawful for three main reasons: (1) the School Board itself already publicly disclosed “Student JH” in its own meeting minutes; (2) BCSD has routinely released settlement amounts in past years (Exhibits C and D show examples from 2017 and 2019); and (3) the Georgia Attorney General’s (AG — the state’s chief lawyer) office, in correspondence attached as Exhibit F, has already told BCSD that the case it relies on — Mullins v. City of Griffin — does not support withholding the figure.
The Complaint asks the court to (a) declare that BCSD violated the Open Records Act, (b) order the District to produce the settlement amount, and (c) award the newspaper its attorney’s fees under O.C.G.A. § 50-18-73(b) (O.C.G.A. stands for “Official Code of Georgia Annotated” — Georgia’s compiled state statutes; § means “section”), Georgia’s fee-shifting statute for open-records cases.
At a glance
| Field | Value |
|---|---|
| Filed | August 4, 2025 |
| Filed by | Joy Ramsingh (Ramsingh Legal, Macon) for Plaintiff |
| Document type | Complaint with Exhibits A-F |
| Pages | Complaint + six exhibits |
| Served on | Bibb County School District (later waived on 8/14/2025) |
| Docket event | Opens the case; Civil Action No. 2025-CV-083495 |
Deep dive — legal concepts, explained
What is a Complaint?
A complaint is the first document filed in almost every civil lawsuit. It does four things: it tells the court who is suing whom; it lays out the facts the plaintiff believes happened; it identifies the laws that were allegedly broken; and it tells the court what the plaintiff wants the judge to do about it (this last part is called the “prayer for relief”).
A complaint is not evidence. It is a set of allegations — the plaintiff’s version of events. The defendant gets to respond with an Answer, admitting some allegations and denying others. The case then proceeds through discovery, motions, and, if needed, trial. See also the glossary for related terms.
The Open Records Act
Georgia’s Open Records Act (O.C.G.A. § 50-18-70 et seq. — Latin for “and following,” meaning “section 50-18-70 and the sections after it”) is the state’s freedom-of-information law. It starts from a strong presumption: records made or received by a public agency in the course of its work are public and must be produced on request, usually within three business days. An agency that wants to withhold a record has to point to a specific exemption in the statute.
When a requester believes an agency has unlawfully withheld a record, the statute lets the requester file a lawsuit in superior court. If the requester wins, the court “shall” award reasonable attorney’s fees — unless the agency proves it acted with “substantial justification.” That fee-shifting rule (§ 50-18-73(b)) is the engine that makes private enforcement of Georgia’s sunshine law possible, because it means journalists and ordinary citizens do not have to absorb their own legal costs to pry loose a public record.
Why the 2024 JH settlement matters
Settlements paid by public school districts are paid with taxpayer money. In most Georgia districts, when a lawsuit or claim settles, the dollar amount and the fact of settlement appear in board minutes, bond disclosures, or insurance filings as a matter of routine transparency.
Here, BCSD’s own Board of Education publicly voted to approve the “Student JH” settlement at its July 18, 2024 public meeting. The minutes (Exhibit E) name “Student JH” by those initials and record a unanimous vote. What the District has refused to disclose is only the dollar figure attached to that already-public vote. The plaintiff’s theory is simple: a public body cannot vote on a dollar amount in public and then claim the dollar amount is a private education record.
What FERPA actually protects (briefly)
FERPA — the federal Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g (U.S.C. stands for “United States Code” — the federal statute book) — protects the privacy of “education records.” Those are records directly related to a student that are maintained by a school: grades, disciplinary files, IEPs (Individualized Education Programs), health information in the student’s file, and so on. FERPA conditions federal education funding on schools keeping those records confidential unless a parent consents or a specific exception applies.
FERPA does not categorically seal every document that mentions a student. Courts and the U.S. Department of Education (US DoE — the federal agency that administers FERPA) have long recognized that settlement agreements between a district and a student’s family are not automatically “education records” — particularly where the financial terms do not themselves reveal educational information like grades, disabilities, or discipline. The Complaint argues that a bare dollar figure, released in connection with a settlement the Board already publicly approved, is not the kind of information FERPA was written to protect.
The exhibits explained (A–F)
- Exhibit A — The ORA Request (the Open Records Request, or ORR — the formal written ask for public records). Reporter Laura Corley’s June 2, 2025 email asking for the 2024 settlement dollar amounts and explicitly stating she is “not seeking access to any other information within any settlement agreements, only the dollar amounts.”
- Exhibit B — The Denial. The June 5, 2025 email response from BCSD Chief Communications Officer (and spokesperson) Stephanie Hartley refusing the request, followed by Corley’s reply seeking the legal basis.
- Exhibit C — 2019 Board Minutes. Board minutes from February 28, 2019 showing that BCSD has historically disclosed settlement amounts with named students in its public minutes.
- Exhibit D — 2017 Board Minutes. Board minutes from October 19, 2017 showing the same pattern of prior disclosure.
- Exhibit E — 7/18/2024 JH Minutes. The July 18, 2024 board minutes stating “Settlement for Student JH (ACTION). The Board voted unanimously to approve this action item.” This is the public document that names “Student JH” by those initials.
- Exhibit F — The AG Letter. April 24, 2025 correspondence from the Georgia Attorney General’s office informing both Corley and counsel for the District that, in the AG’s informal view, Mullins v. City of Griffin does not support the District’s non-disclosure position.
Why this matters
The Complaint is the scaffolding the rest of the lawsuit is built on. Every later filing — the Answer, the motion for partial summary judgment, the discovery — is a response to the allegations and legal theories first advanced here. If the case ends in the newspaper’s favor, it would establish, at the Bibb County Superior Court level, that Georgia school districts cannot use FERPA as a blanket shield for settlement dollar figures tied to publicly approved board actions.
The filing also frames the fight as one about consistency: BCSD released settlement amounts in 2017 and 2019, publicly named “Student JH” at its own July 2024 meeting, and was told by the state Attorney General’s office that its chosen legal authority does not support withholding. Those three factual moves are the plaintiff’s strongest cards going into discovery and summary judgment.
Read the original
Part of Court Filings · Case No. 2025-CV-083495 · Bibb County Superior Court