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PR 17-43 Riggs v. Coastal Resources Management Council – No Violation

The Complainant alleged that the CRMC violated the APRA when it failed to adequately respond to requests for documents. We found that the Complainant's email to the CRMC's Executive Director was not a valid APRA request because it failed to comply with the CRMC's APRA procedures, contained a mixture of questions and requests incongruous with a valid APRA request, and was insufficiently independent from a prior APRA request made by a third party. We also found that the Complainant's phone call and email with outside legal counsel to the CRMC failed to constitute cognizable APRA requests. We noted that Complainant did not intend these communications to be APRA requests and that the outside legal counsel had no authority "to grant or deny persons or entities access to records." R.I. Gen. Laws § 38-2-3.16; see also Farinelli v. City of Pawtucket, PR 17-19. Accordingly, we found no violation.

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