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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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