The Appellate Division ruled today that a public body correctly withheld, under OPRA’s privacy provision, the home addresses, telephone numbers and email addresses of individuals who had submitted OPRA requests. Wolosky v. Somerset County.

The court determined that although OPRA requests themselves are government records, this does not mean that personal information shown in an OPRA request must be disclosed. Instead, OPRA’s privacy protection applies to such information. The Appellate Division conducted the balancing test required under OPRA’s privacy provision, and concluded that requestors’ personal contact information should not be disclosed.

Notably, the court indicated that the requestor here had shown no genuine need to obtain disclosure of this personal information. This case is another example of how some requestors seek to use OPRA to infringe on individuals’ privacy rights.

The Appellate Division’s opinion continues the recent trend of courts holding, in non-precedential opinions, that home addresses are protected by OPRA’s privacy section. See this post for further discussion of this case law.