Amy Silverman v. Ades

Summary

The court held that investigative journalists may qualify as persons engaged in bona fide research under the statutory exception permitting limited access to otherwise confidential adult-protective-services records. Bona fide research requires a genuine, good-faith study aimed at acquiring knowledge, discovering facts, or testing ideas concerning reporting or stopping abuse, exploitation, or neglect of vulnerable adults, while ADES retains discretion to deny or limit disclosure for legitimate public-policy reasons. The court vacated the appellate decision, affirmed denial of ADES's motion to dismiss, reversed the judgment compelling production, and remanded for factual development and application of the governing standards.