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PR 17-05 Piskunov v. Town of Narragansett No Violation

The Complainant alleged that the Town violated the APRA when it withheld the requested last ten internal affairs reports completed by the Town Police Department. Consistent with Direct Action for Rights and Equality v. Gannon (DARE), 713 A.2d 218 (R.I. 1998), citizen-initiated complaints were more likely to further the public interest than other kinds of internal affairs reports. Here, the evidence indicated that of the last ten internal affairs reports completed, only three were citizen-initiated complaints and two of those complaints were either withdrawn or not pursued by the complainant. The evidence also revealed that the Complainant failed to articulate any public interest. Accordingly, based upon the undisputed evidence presented, we failed to find any evidence that the balancing scale tipped in favor of public disclosure and, as a result, found no violation.

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