Summary of Latest GRC Decisions

This blog will summarize the final decisions rendered each month by the GRC. The summaries below are of the cases decided at the GRC’s recent May 2015 meeting. Note that at each meeting the GRC also issues a number of interim decisions, which will not be included in a summary until they become final. Occasionally, interim decisions will discussed in separate posts, where they deal with an interesting issue (such as here).

Final GRC decisions from May 2015 meeting:

Carter v. Franklin Fire Dist. Request for all purchase orders, vouchers and warrants held to be an invalid blanket request.

Scheeler v. Salem Special Services School Dist. Due process petitions are exempt from disclosure as student records. Also, custodian erred in not disclosing redacted “Rice notices.”

Sorce v. Stafford Twp. Custodian erred in not providing immediate access to requested invoices. Also held that the invoices, which were eventually provided to the requestor, were over-redacted.

-Martinez v. Edison Bd. of Ed. Request for emails held invalid because sender and recipient were not identified. Also, the requested student records were exempt from disclosure.

Mitchell v. DMAVA Bid proposal held exempt from disclosure prior to award of contract, in accordance with NJ DMAVA regulation.

Lare v. Lower Twp. Denial of request upheld because no responsive records existed.

Baker v. Union County Prosecutor A 3d-party’s presentence report held exempt from disclosure.

Kovacs v. Woodbridge Police Dept. Request for all police reports containing a certain address held to be invalid for not identifying specific record.

Wares v. West Milford Twp. Complaints filed about police officers and police internal affairs complaints are exempt from disclosure.

Hayes v. NJ Dept. of Corrections Investigative notes and classification file concerning incident involving an inmate held confidential under exemption for safety and security.

Williams v. Passaic County Prosecutor Denial of request upheld because responsive record did not exist.

Graumann v. Newfield Police Dept. The custodian erred by not responding timely and in writing to the request, but the GRC determined that there was no denial of access because the custodian eventually did provide the requested records. Also, no penalty was imposed on the custodian because the GRC found she did not intentionally violate OPRA.

Garrett v. Dept. of Banking and Ins. Complaint file held exempt from disclosure, in accordance with NJ DOBI regulation.

The next GRC meeting is scheduled for June 30th.

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