Matter of New York Civ. Liberties Union v. New York State Off. of Ct. Admin.

Summary

The Court of Appeals held that the parties had identified a reasonably described subset of records responsive to NYCLU's FOIL request, consisting of documents similar to the memorandum circulated between OCA's Counsel's Office and UCS judges. It further held that OCA could not withhold that entire subset under a blanket attorney-client privilege claim because it had not established an attorney-client relationship with all UCS judges. The matter was remitted for review of any specific privilege claims, including in camera review if necessary.