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PR 17-07 Harris v. City of Providence No Violation

Complainant alleged that the City violated the APRA when it: (1) redacted handwritten notes on released documents; (2) failed to produce a City's employee's calendar; (3) failed to produce certain payroll documents for a particular City employee; and (4) charged an allegedly excessive fee for search, review, and redaction of the produced documents based on the short elapsed time between pre-payment and production. Based on our in camera review, we found that the redacted handwritten notes were not responsive to the Complainant's APRA request and thus the redaction did not violate the APRA. Additionally, based on the City's uncontroverted affidavits, we found no evidence that the calendar document existed. With respect to the requested payroll documents, we found that the City's search was reasonably calculated to discover all responsive documents. Finally, we found that undisputed evidence demonstrated that the City's charge for search, review, and redaction corresponded to work done before the estimate was sent to the Complainant. Accordingly, we found no violation.

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