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PR 16-09 Scalzi v. Town of North Smithfield No Violation

The Complainant alleged that the Town violated the APRA when it failed to include all documents responsive to her APRA request dated March 30, 2015. The APRA states that, unless exempt, all records maintained by any public body shall be public records and every person shall have the right to inspect and/or copy such records. See R.I. Gen. Laws 38-2-3(a). Accordingly, our inquiry concerns not whether the Town has provided all requested documents, but rather whether the Town has conducted an adequate and appropriate search to determine whether the Town maintains the requested records. In fact, the linchpin of our inquiry concerns the reasonableness of the Town's search. The evidence demonstrated that the Town spent approximately four (4) hours conducting a search of 110 files and produced records responsive to the APRA request. There is no evidence that the Town's search was inadequate. Accordingly, we find no APRA violation.

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