The Complainant alleged that Rhode Island College ("RIC") violated the APRA when it did not provide all documents responsive to his APRA request. In particular Complainant alleged that RIC had not provided a certain responsive email. The record revealed that after the Complaint was filed, RIC provided Complainant the email that he alleged had been withheld, and there was no evidence of any other responsive records that had not already been provided to Complainant. This Office has previously determined it unnecessary for us to consider whether a public body violated the APRA when a complainant receives the subject document after filing an APRA complaint and where there is no evidence of a willful and knowing or reckless violation. The reason for this conclusion is because, even assuming a violation occurred, the APRA only provides for two types of remedies: injunctive relief and civil fines for a willful and knowing or reckless violation. See R.I. Gen. Laws § 38-2-9(d). Since the Complainant was provided the email he alleged had been withheld, we found no need for injunctive relief. We also found no evidence that RIC's actions were willful and knowing or reckless in the circumstances of this case.
