In the Matter of Khalib Gould, Appellant v. New York City Police Department, Respondents; In the Matter of…

Summary

The Court held that complaint follow‑up reports are not categorically exempt as intra‑agency material and that police activity logs are agency records subject to FOIL; it reversed the orders in Gould and DeFelice, modified the order in Scott, and remanded all three proceedings for further determination. Justice Bellacosa dissented, arguing that the majority’s approach creates an unmanageable discovery regime and should be affirmed.