Elizabeth Mason, Plaintiff-Appellant v. City of Hoboken, James Farina, City Clerk of the City of Hoboken…

Summary

The Court affirmed the Appellate Division, holding that OPRA actions must be filed within a 45‑day statute of limitations and that attorney’s fees are only available when a requestor shows a causal nexus between the lawsuit and the agency’s disclosure, with the burden shifting to the agency if it fails to respond within seven business days. The plaintiff’s claims were untimely and she did not satisfy the fee‑shifting test, so no fees were awarded.