University of Pittsburgh v. Dept. of Labor & Industry - Commonwealth Court - April 12, 2006
http://www.courts.state.pa.us/OpPosting/CWealth/out/1440CD05_4-12-06.pdf
An employee can get access to her/his personnel file under the Personnel File Inspect Act, 43 P.S. 1321 et seq. In this case, however, access to outside references for an academic tenure evaluation was denied. The court said that such documents were excluded from the definition of "personnel file," since they were "letters of reference."
