2016 Case Law Update

The first third of 2016 has seen the issuance by the courts of several major OPRA opinions. Notably, all of these rulings upheld the decision of the custodian.

-Paff v. Galloway Tp.

As I’ve previously said, this is the most important OPRA opinion in many years. The Appellate Division held, for the first time, that a public body is not required by OPRA to compile information from its computerized records to produce a requested report.

C.G. v. Winslow Tp.

This trial court opinion is the first New Jersey published opinion on an issue that often comes up under OPRA– the extent of redactions that must be made, under federal law, of “personally identifiable information” within educational records concerning students. The court ruled that the school board had properly redacted parents’ and students’ initials, as well as the case docket numbers, shown on settlement documents.

O’Boyle v. Longport

The Appellate Division upheld the confidentiality of information identifying properties that have made FEMA claims for flood damage. Again, this type of OPRA request often is made, but this is the first Appellate Division opinion to deal with this issue.

 

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