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PR 17-14B Hicks v. Rhode Island Commission on the Deaf and Hard of Hearing not willful and knowing or reckless

This supplemental finding addressed whether the APRA violations found in Hicks v. Rhode Island Commission on the Deaf and Hard of Hearing, PR 17-14 were willful and knowing, or reckless. After reviewing all the evidence presented, and although a close question, we found insufficient evidence of a willful and knowing, or reckless, violation. The RICDHH's actions did not indicate a "specific intent" to violate the APRA or a conscious disregard for the APRA's requirements. See Carmody v. Rhode Island Conflict of Interest Comm'n, 509 A.2d 453, 459 (R.I. 1986); see also Catanzaro v. East Greenwich Police Department, PR 13-08.

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