In an opinion issued today, the Appellate Division upheld the redaction of school board members’ home addresses under OPRA’s privacy exemption. Scheeler v. NJ Dept. of Ed.

The addresses appeared on financial disclosure statements filed by local school board members with the School Ethics Commission. The GRC determined that the addresses should be redacted to protect these individuals’ privacy interests. In reaching this decision, it noted that the School Ethics Law does not require that home addresses be shown on the disclosure statement.

The Appellate Division applied OPRA’s privacy balancing test and held the addresses were properly redacted. It found that the school board members had a strong privacy interest in their addresses here, because of the existence of other personal information on the disclosure statement form, such as their personal finances. The court also concluded that the requestor had shown no public interest would be served by disclosure of the addresses.

As I’ve discussed before, see this post, New Jersey courts have yet to resolve the important issue of whether OPRA requires disclosure of home addresses. Unfortunately, Scheeler is not a precedential, published opinion, so there remains no definitive court ruling on this question.