New York Court of Appeals

Matter of New York Civ. Liberties Union v. City of Rochester

February 20, 202543 N.Y.3d 543

Summary

The Court of Appeals held that the personal-privacy exemption does not permit a law-enforcement agency to categorically withhold disciplinary records concerning complaints that were not substantiated. The 2020 statutory amendments require agencies to assess each record individually, withholding or redacting only material supported by a particularized and specific privacy justification. The court affirmed the order directing the Rochester respondents to conduct that individualized review.