New York Court of Appeals

Matter of Wagner v. New York City Dept. of Educ.

October 21, 20252025 NY Slip Op 05783

Summary

The Court of Appeals reversed the Appellate Division’s denial of a FOIL request, holding that the Department of Education’s refusal was based on an improper conflation of the reasonable‑description requirement with the agency’s ability to retrieve records with reasonable effort, and remanded for a new determination.