## Facts

- Randall Buchanan was found murdered in Blair County, Pennsylvania; the homicide investigation remained open and unsolved.
- The Blair County Coroner prepared an autopsy report containing detailed, non-public information about the victim’s condition.
- A newspaper, the Altoona Mirror, requested access to the autopsy report as a public record under Pennsylvania’s Coroner’s Act, which required coroners to deposit official records for public inspection after the statutory filing period.
- The Blair County District Attorney sought to seal the autopsy report, asserting disclosure would compromise investigative efforts.
- At a hearing, witnesses for the Commonwealth testified that non-public autopsy details can be used to evaluate tips and confessions and to identify suspects or witnesses.
- The trial court denied the motion to seal and ordered disclosure without conducting an in camera review or making specific findings about investigative harm.

## Issues

1. Whether autopsy reports are public records subject to disclosure under the Coroner’s Act when a homicide investigation remains pending.
2. Whether a court has common-law authority to restrict access to an otherwise public autopsy report to protect an ongoing criminal investigation.
3. What standard and procedures govern any restriction, including whether in camera review and factual findings are required.

## Decision

- The Supreme Court of Pennsylvania held that autopsy reports are presumptively public “official records” under the Coroner’s Act.
- The Court recognized a limited common-law judicial power to restrict disclosure when necessary to protect an active criminal investigation.
- The Court approved a “substantial hindrance” (or “substantial impediment”) standard: disclosure may be restricted only upon a concrete showing that release would substantially hinder the pending investigation.
- The Court required trial courts to conduct an in camera review of the report and to make specific factual findings explaining whether disclosure would substantially hinder the investigation.
- The Court remanded for the trial court to apply the standard using those procedures.

## Legal Principles

- Autopsy reports held by a coroner are presumptively public records subject to inspection under the Coroner’s Act after the statutory filing requirements are met.
- Courts retain common-law authority to restrict access to public records on a case-by-case basis to prevent substantial interference with criminal investigations.
- Sealing requires more than speculation; the government must show that disclosure would substantially hinder an active investigation.
- Before limiting access, a court must review the contested material in camera and enter specific, reviewable factual findings; any restriction should be no broader or longer than necessary.

## Conclusion

Pennsylvania law treats autopsy reports as public records, but a court may temporarily restrict access when the Commonwealth proves disclosure would substantially hinder an ongoing criminal investigation, and only after in camera review and specific factual findings supporting the restriction.


In re Buchanan, 880 A.2d 568 (Pa. 2005)