In Cuccinelli v. Rector & Visitors of Univ. of Va., 722 S.E. 2d 626 (2012), the state Supreme Court held that the Virginia Attorney General could not issue a CID to the University of Virginia (UVA) under the FATA because the university was not a “person” under the Act. Virginia Attorney General Ken Cuccinelli issued two CIDs in 2010 under the FATA to UVA for records related to grant applications by a climate scientist who was a former assistant professor at the university. Cuccinelli alleged that the scientist may have violated the FATA by manipulating data on climate change.
28 Feb '13