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PR 15-22 Flaherty v. Rhode Island Department of Transportation – No violation

The Complainant alleged the Rhode Island Department of Transportation ("RIDOT") violated the APRA when it denied her APRA request seeking documents regarding the "Draft Feasibility Study for Phase 4 Canonchet Farm Bike Path." The RIDOT denied the request pursuant to R.I. Gen Laws § 38-2-2(4)(K) as a "draft." Rhode Island General Laws § 38-2-2(4)(i)(K) exempts from public disclosure, "[p]reliminary drafts, notes, impressions, memoranda, working papers, and work products; provided, however, any document submitted at a public meeting of a public body shall be deemed public." As no evidence was submitted that this draft was submitted at a public meeting, we found no violation.

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