Commissioner of Public Safety v. Freedom of Information Commission

Summary

The court held that, during a pending criminal prosecution, the Freedom of Information Act makes the arrest-record provision the exclusive source of a law enforcement agency's disclosure obligations. The 1994 amendment increased required disclosure by requiring the police to provide the basic arrest information plus at least one meaningful narrative item, such as a news release, but did not make the general disclosure and law-enforcement-exception provisions independently applicable to other prosecution-related records. The court also held that the commission's contrary interpretation was not reasonable and therefore was not entitled to administrative deference.