In Moses Afonso Ryan, Ltd v. City of East Providence, we reviewed the Complainant's Access to Public Records Act ("APRA") complaint against the City of East Providence ("City") and concluded that the City violated the APRA when it improperly denied the Complainant's APRA request. See R.I. Gen. Laws § 38-2-7. The City was allowed to provide an explanation as to why the violation should not be considered knowing and willful, or reckless. See R.I. Gen. Laws § 38-2-9(d). After reviewing the City's supplemental response and the evidence presented, it appeared that the City's decision to deny access was the result of comingling the APRA and the Open Meetings Act, which led to the City's conclusion that the APRA request was not made to a public body. While we rejected this reasoning, we are satisfied that the violation was not willful and knowing, or reckless.
