Patricia Gilleran, Plaintiff-Respondent v. the Township of Bloomfield and Louise M. Palagano

Summary

The Supreme Court of New Jersey reversed the Appellate Division, holding that New Jersey’s Open Public Records Act (OPRA) does not impose a blanket exemption for all security‑camera footage but that the Township’s security exemptions apply here because disclosure would reveal the capabilities and vulnerabilities of its surveillance system. The Court affirmed the agency’s burden to show that release would jeopardize security and found the Township’s certification sufficient, while remanding for further common‑law right‑of‑access analysis. Chief Justice Rabner’s dissent argues the statute requires a specific showing of risk and that the majority’s categorical exemption is contrary to OPRA’s plain language.