In a published, precedential opinion, the Appellate Division held that the right to request records under OPRA is not limited to citizens or residents of New Jersey. Scheeler v. Atlantic County Municipal JIF, etc.

The court’s ruling is consistent with the view I had previously expressed, that OPRA cannot be reasonably interpreted as applying only to citizens of New Jersey. Judge Reisner’s opinion cogently demonstrates that the Legislature did not intend to impose a citizenship requirement; instead, the statute allows any person to make an OPRA request.