New York Court of Appeals
In the Matter of Peter L. Rattley v. New York City Police Department
July 2, 200196 N.Y.2d 873
Summary
The New York Court of Appeals reversed the Appellate Division and reinstated the Supreme Court's dismissal of the plaintiff's FOIL suit, holding that the police department satisfied the certification requirement of Public Officers Law § 89(3) without a detailed search description or personal statement. Accordingly, the article 78 proceeding was properly dismissed as moot.