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PR 17-50 Starnino v. Narragansett Police Department No Violation Found

The Complainant alleged the Narragansett Police Department violated the APRA when it improperly denied his request for a specific incident report that did not culminate in an arrest. The APRA request implicated R.I. Gen. Laws 38-2-2(4)(D)(c), which exempts from public disclosure records maintained by law enforcement agencies for criminal law enforcement purposes where disclosure "could reasonably be expected to constitute an unwarranted invasion of personal privacy." There was some privacy interest concerning the individuals named in this incident report. We determined that the privacy interest outweighs the public interest in disclosure. See Direct Action for Rights and Equality v. Gannon, 713 A.2d 218 (R.I. 1998). The Complainant cited no "public interest" in disclosure and even a minimal privacy interest outweighs a non-existent "public interest." Additionally, since the report related to a specific and identifiable incident, it was not susceptible to redaction. See Pawtucket Teachers Alliance v. Brady, 556 A.2d 556, 559 (R.I. 1989)

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