Appellate Division Upholds Redaction of Students’ Initials Under Privacy Exemption

In an unpublished opinion, the Appellate Division rejected the claim that OPRA requires disclosure of students’ initials, where their initials appear on a public record. Wolosky v. Sparta Bd. of Ed.

The records in question were school board attorney invoices, which contained references to various students, identified by their initials. The court upheld the redaction of the initials under OPRA’s exemption for privacy. The court determined that disclosing the initials could lead to identifying the students, and students’ strong privacy interests outweighed the requestor’s interest in disclosure.

Notably, the Appellate Division relied on a 2016 published trial court opinion, C.G. v. Winslow Tp. Bd. of Ed., which had similarly rejected the argument that OPRA mandates disclosure of students’ initials. See here for a discussion of the C.G. case.

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