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PR 19-26 Law v. Town of Smithfield - Violation Found

The Complainant alleged the Town violated the APRA when it denied her request for emails between the Town Council President and Town Manager and when its denial failed to articulate its APRA appeal procedures. Based on our in camera review, we found the Town did not violate the APRA when it withheld responsive emails sent or received during the Town Council President's term related to his official duties as Town Council President. We found the Town's denial lacked any language concerning its APRA appeal procedures and thus violated the APRA. We did not find evidence to support a willful and knowing, or alternatively reckless, violation nor did we find injunctive relief appropriate. VIOLATION FOUND.

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