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PR 18-38 The Providence Journal v. Rhode Island Secretary of State - No Violation

The Complainant alleged that the SOS violated the APRA when it produced the requested state voter list but withheld the days and months of voters' dates of birth. We first found that R.I. Gen. Laws 17-6-5 does not require disclosure of the full dates of birth. We next weighed the public interest in disclosure against the privacy interest pursuant to R.I. Gen. Laws 38-2-2(4)(A)(I)(b). On the facts presented, we found little evidence that the information captured by the broad request would further the public interest. As such, we concluded on this record that the privacy interest outweighed the public interest and that the APRA does not mandate disclosure of the full dates of birth here. However, we did not foreclose that full dates of birth could advance a public interest on a different record. We found no violations.

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