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PR 20-01 Providence Journal v. Executive Office of Health and Human Services

Complainant alleged EOHHS violated the APRA when it withheld documents responsive to its APRA request pursuant to three APRA exemptions: R.I. Gen. Laws 38-2-(4)(A)(I)(a), 38-2-42(4)(E), and 38-2-2(4)(K). This Office set forth the relevant law and engaged in a lengthy in camera review of over 1,000 pages of responsive documents submitted by EOHHS. Based on our in camera review, we concluded that EOHHS properly withheld a number of documents and improperly withheld one document. Additionally, there are a number of documents for which we cannot yet determine whether withholding the documents was proper under the APRA. Our evaluation of EOHHS's asserted basis for withholding those documents would benefit from additional information and analysis in light of the legal standards set forth in our finding, and we accordingly instructed EOHHS to provide supplemental information as described in the finding.

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