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PR15-06 Nangle v. Town of North Smithfield – NO VIOLATION

The Town of North Smithfield ("Town") did not violate the APRA when it denied the Complainant's APRA request seeking the names and email addresses of individuals who receive the Town's newsletter. We concluded, based upon the evidence presented, that disclosure of the names and email addresses of those who subscribe to a Town's newsletter will not shed any light on government operations. Balanced against a minimal, if any, "public interest," we perceive a greater privacy interest. See Fuka v. RI Dept. of Environmental Mgmt, 2007 WL 1234484 (the home addresses of licensed fishermen were exempt under the APRA); United States Department of State v. Ray, 502 U.S. 164 (1991)(disclosing names of illegal emigrants constituted clearly unwarranted invasion of personal privacy); Bibles v. Oregon Natural Desert Ass'n, 519 US 355 (1997)(mailing list containing names and address where newsletter sent not a public record).

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