People for the Ethical Treatment of Animals, Inc. v. Freedom of Information Commission

Summary

The court held that, when the Department of Administrative Services makes the initial safety-risk determination under the Freedom of Information Act, the Freedom of Information Commission and reviewing courts must defer to that determination unless it is frivolous, patently unfounded, or made in bad faith. The commission applied a sufficiently similar standard, but the trial court had not decided whether the department's determination satisfied the proper standard. The judgment was therefore reversed and the case remanded for that determination.