New York Court of Appeals
In the Matter of Khalib Gould, Appellant v. New York City Police Department, Respondents; In the Matter of…
November 26, 199689 N.Y.2d 267
Summary
The Court held that police complaint follow‑up reports are not categorically exempt as intra‑agency material because they contain factual data, and that police activity logs are agency records subject to FOIL. It also affirmed that the Police Department properly certified the nonexistence of other records. Accordingly, the Court reversed the orders in Gould and DeFelice, modified the order in Scott, and remanded all three matters for further determination of any particularized exemptions.