A government employer may withhold information about an employee’s termination, the Commonwealth Court has ruled, if the record of the employee’s firing contains prior disciplinary history.

In so holding, the split en banc panel reasoned that because disciplinary action against an employee is contained in a government agency’s so-called “personnel file,” which is exempt from disclosure under the state’s Right-to-Know Law, such must be the case for a termination letter that includes information gleaned from the protected material.