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PR 20-07 Farinelli v. City of Pawtucket – Violation Found

The Complainant alleged the City violated the APRA when it withheld two (2) police reports she requested. The City argued that these reports pertained to criminal investigations that did not result in arrests and that disclosure of these reports would constitute an unwarranted invasion of personal privacy. This Office previously issued a finding related to the first of the requested reports, determining that the City did not violate the APRA when it withheld this report because the privacy interests outweighed any public interest in disclosure. We reaffirmed that decision and concluded that the City did not violate the APRA by withholding this report. Based on our in camera review of the second report and corresponding attachments, we found that the City did violate the APRA by withholding this report in its entirety because it implicated a significant public interest that outweighed the privacy interests that were implicated, and certain information implicating privacy interests could be redacted. There was insufficient evidence to support a finding of a willful and knowing, or reckless violation, but this Office directed the City to provide the second report, subject to permissible redactions, at no cost to the Complainant. VIOLATION FOUND.

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