In the Matter of Robert S. Fink, Appellant-Respondent v. Louis J. Lefkowitz, as Attorney-General

Summary

The New York Court of Appeals held that portions of the Deputy Attorney‑General’s nursing‑home investigation manual containing non‑routine investigative techniques are exempt from disclosure under § 87(2)(e)(iv) of the Freedom of Information Law, while routine audit guidance is disclosable. The court affirmed the Appellate Division’s partial exemption and reversed the order requiring disclosure of specific pages that reveal specialized techniques.