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PR 17-39 Conley v. City of East Providence - No Violation

The Complainant alleged that the City violated the APRA when it withheld requested police incident reports regarding a specific juvenile individual. We have consistently held that where an arrest has not taken place, there is a presumption that incident reports are exempt from public disclosure, particularly where juveniles are identified. See R.I. Gen. Laws 38-2-2(4)(D); see also Lassiter v. Pawtucket Police Department, PR 14-18. After weighing the non-asserted public interest in disclosure against any privacy interests, we found that there were significant privacy interests relating to juveniles in the incident reports. Based on our in camera review, we found that these privacy interests could not be adequately protected through redaction. See Pawtucket Teachers Alliance v. Brady, 556 A.2d 556, 559 (R.I. 1989) ("Even if all references to proper names were deleted, the principal's identity would still be abundantly clear from the entire context of the report."). Accordingly, we found no violation.

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