This blog summarizes the final decisions rendered each month by the GRC. The summaries below are of the cases decided at the GRC’s most recent meeting, held at the end of July (see here for summaries of the decisions issued at previous meetings).

-Carroll v. Trenton School Dist.: Custodian’s failure to respond properly to the request was not a knowing and willful violation.

-Dunleavy v. Jefferson Twp. Bd. of Ed.: (1) Custodian’s untimely response was not a knowing and willful violation; (2) One part of the OPRA request, asking whether a particular individual was employed, was an invalid information request.

-Barry v. NJ Transit: Custodian’s untimely response was not a knowing and willful violation.

-Moss v. Newark Zoning Bd.: Custodian lawfully denied the request because the requested records did not exist.

-Caggiano v. Governor’s Office: Custodian properly denied a request for all emails sent to the Governor’s Office by the requestor.

-Demitroff v. Buena Vista Fire Dist. No. 1: Custodian properly denied the request because the document requested was that of a private firm and was not in the agency’s possession.

-Alexander v. NJDOC: Custodian’s failure to provide the requested full name of an employee was not a knowing and willful violation.

-Verry v. Franklin Fire Dist. No. 1: (1) A resolution for no-bid professional services is not subject to OPRA’s “immediate access” provision; (2) Parts of the request were invalid because they did not specify a time frame for the correspondence sought; (3) Requestor was not entitled to attorney fees under the catalyst approach, even though records were released to him after the filing of the GRC complaint, because he filed the complaint without giving the custodian time to respond to his demand for additional records.

-Kimpton v. NJDOC: Custodian properly denied the request under the security exemption.

-Musgrave v. NJ State Police: There was no unlawful denial, as the request was properly denied under the law existing at the time of the request, and the records were subsequently released.

-Muata v. NJDOC: Denial of the request was upheld because no responsive records existed.

-Garcia v. NJDOC: Custodian properly denied the request as an invalid research request.

-Verry v. Franklin Fire Dist. No. 1 (#2014-387): The request for text messages was properly denied because no responsive records existed.

-Schultz v. NJ State Police: (1) a portion of the request, seeking all documents related to a certain investigation ,was properly denied as overbroad; (2) Autopsy reports are not criminal investigatory records and therefore must be disclosed; (3) Other reports and records were properly withheld as criminal investigatory records.

-Giambri v. Sterling H.S. Dist. (#2014-394): Custodian’s failure to provide immediate access to certain contracts and salary information was not a knowing and willful violation.

-Giambri v. Sterling H.S. Dist. (#2014-397): The request was properly denied as overly broad and requiring research.

-Gartner v. Middlesex Boro: Custodian’s belated disclosure of executive session minutes was not a knowing and willful violation.

-Scheeler v. NJDOE (#2015-16,17): Custodian’s insufficient response to the request was not a knowing and willful violation.

-Scheeler v. NJDOE (#2015-19): Custodian properly requested an extension of time to respond to the request.