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PR 16-48 Providence Journal v. Pawtucket Police Department No Violation

The Providence Journal, alleged the Police Department violated the APRA when it denied its APRA request, which sought "a copy of the police report from Feb. 11 on the murder-suicide of [Mr. and Mrs. Doe] and Feb. 4 report made by [Ms. Doe] alleging threats by [Mr. Doe]." In National Archives and Records Administration v. Favish, 541 U.S. 157 (2004), the United States Supreme Court considered a similar public interest argument. Even if we assume the Complainant satisfied the Favish standard and presented evidence that disclosure would advance some public interest, case law and our in camera review makes clear that in this case, and based upon the evidence presented, the surviving family members' privacy interests outweigh the public interest and no reasonable segregable portion can be provided. See R.I. Gen. Laws 38-2-3(b).

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