The Appellate Division recently held, in a case of first impression, that Use of Force Reports (UFRs) involving juveniles must be disclosed under OPRA, with redaction of the name of the juvenile. Digital First Media v. Ewing Tp.

The OPRA request sought UFRs from Ewing Township in connection with the arrest of a minor. Ewing denied the request, taking the position that the UFR was a juvenile record and therefore was completely confidential. The court rejected this argument. It determined, consistent with the position of the Attorney General, that disclosure of the UFR, with redaction of the juvenile’s identity, satisfies the laws mandating preservation of a juvenile’s confidentiality.

This is clearly the correct result. UFRs are public records under OPRA. If a portion of a UFR contains confidential information, that does not make the entire record exempt; instead, that part of the record should be redacted, as OPRA requires with regard to all other publicly-accessible records.