Alex Rosetti v. Ramapo-Indian Hills Regional High School Board of Education

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 27, 2025
DocketA-1466-23
StatusPublished

This text of Alex Rosetti v. Ramapo-Indian Hills Regional High School Board of Education (Alex Rosetti v. Ramapo-Indian Hills Regional High School Board of Education) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alex Rosetti v. Ramapo-Indian Hills Regional High School Board of Education, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1466-23

ALEX ROSETTI,

Plaintiff-Appellant,

v. APPROVED FOR PUBLICATION RAMAPO-INDIAN HILLS January 27, 2025 REGIONAL HIGH SCHOOL APPELLATE DIVISION BOARD OF EDUCATION1 AND THOMAS LAMBE, IN HIS OFFICIAL CAPACITY AS RECORDS CUSTODIAN,

Defendants-Respondents. __________________________

Argued October 8, 2024 – Decided January 27, 2025

Before Judges Sumners, Susswein and Bergman.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Docket No. L-1383-23.

Donald M. Doherty, Jr. argued the cause for appellant.

Johnathan F. Cohen argued the cause for respondents (Plosia Cohen LLC, attorneys; Johnathan F. Cohen, of counsel and on the briefs).

1 Improperly pled as Rampapo-Indian Hills Regional High School Board of Education The opinion of the court was delivered by

SUMNERS, JR., C.J.A.D.

The issue before this court, one of first impression, is whether the Open

Public Records Act (OPRA or Act), N.J.S.A. 47:1A-1 to -13, compels the

disclosure of email logs of public officials' personal computers discussing public

business. The trial court's order denied plaintiff Alex Rosetti's OPRA request

of defendants Ramapo-Indian Hills Regional High School Board of Education

(Board or District) and Thomas Lambe, the Board's records custodian, seeking

email logs from the personal computers of past and current Board members

(collectively Board members) discussing Board business. The court decided the

email logs were not government records and, if they were, they are too

burdensome to produce.

We reverse the trial court's order and remand. We conclude the email logs

on private servers are government records under N.J.S.A. 47:1A-1, and are

disclosable based on Ass'n for Government Responsibility, Ethics &

Transparency v. Borough of Mantoloking, 478 N.J. Super. 470, 489 (App. Div.

2024), where we held "OPRA's broad reach can include emails concerning

A-1466-23 2 government business, sent to or from personal accounts of government officials

–– if the emails fall within the definition of government records."

On remand, the Board members must search their personal email accounts

to determine if the sought-after email logs are available. If they determine the

email logs are unavailable or there are burdens in producing them, they must

produce Paff I2 certifications. The trial court must then decide if a fact-finding

hearing is needed. After giving Rosetti the opportunity to respond, the trial

judge must then decide if a fact-finding hearing is necessary. Moreover, the

court must be satisfied the parties made good faith efforts to reasonably resolve

their dispute. Only after this process occurs can the court decide if production

of the email logs should be provided, or if it would be too burdensome to

provide.

I.

In January 2023, Rosetti filed an OPRA request with the Board, seeking:

[1] All comments submitted by the public comments form received by the Board from August 1, 2022 through to the date [for] the response. The response should include the name, email, town and the question or comment of the sender.

2 Paff v. New Jersey Dep't of Labor, 392 N.J. Super. 334, 341 (App. Div. 2007) (Paff I). A-1466-23 3 [2] Email logs of all past and current Board members for all email accounts in which they have conducted or discussed Board of Education matters or business during the time frame of November 1, 2022 through to the date of the response. The email log should contain the sender, recipient, those copied ("cc") or blind copied ("bcc"), the date, time, subject and identify the existence and name of any attachment.

When the Board did not timely respond to the requests, Rosetti filed an order to

show cause and verified complaint against the Board in the Law Division,

claiming entitlement to the email logs under OPRA.

In response, the Board contended that Rosetti's requests should be re-

organized in the following manner:

(1) All comments submitted by the public comments form received by the Board from August 1, 2022, through to the date of the response. The response should include the name, email, town and the question or comment of the sender.

(2) (a) Email log[s] of Board members from Board server[s]; and

(2)(b) Email log[s] of Board members from their own personal email addresses. The parties reached a settlement regarding all but the Board members' email logs

pertaining to their own personal email addresses.

After reviewing the Board members' email logs from the Board's servers,

Rosetti submitted a certification to the trial court attesting: "[I]n the log that

A-1466-23 4 was supplied there are dozens of redactions demonstrating Board members using

their District-supplied email accounts to communicate with other Board

members['] personal email accounts and even sending information to their own

personal accounts." To further support his request, Rosetti cited to "a newspaper

article detailing the intricate, involved and expansive agenda the [Board] was

able to vote upon without any significant discussion at its reorganization

meeting." He thus reasoned "that communications regarding Board business are

taking place outside the realm of the District[-] controlled email accounts."

The Board opposed the request with a certification by John Chang, the

Board's Director of Technology, claiming email logs from private servers pose

distinct challenges because each server may have their own administrative

settings. The different settings, Chang noted, "make it impossible or

extraordinarily time consuming to create logs of any kind." He added, "[e]ven

if I could figure out how to generate a log for some of these email serv [ers], it

could potentially take me hours to construct each one and I would be unable to

ensure the integrity of the data (e.g., I cannot recover deleted emails in the same

way I can on the District Workspace service)." As such, Chang contends his

ability to generate logs on private servers is "difficult if not impossible" for

many types used by the Board members.

A-1466-23 5 The trial court agreed with the Board and denied Rosetti's request for the

Board members' personal email logs on the basis that it exceeded the purview

of OPRA. The court stated in its thorough written decision that "[t]he [Paff II3]

Court did not opine email logs from third-party email accounts were required

and nothing in the Court's opinion supports the compelled production of same."

The court distinguished Rosetti's request from the one in Burnett v. Gloucester

County, 415 N.J. Super. 506 (App. Div. 2010), reasoning that there, the "third-

party" government records were maintained by the county's agents, and, thus,

imputed to the government. The court continued that "[w]hile it is undeniable

that [Rosetti] has a right to the email correspondences from the private email

accounts of the Board members, that right cannot be extended to include email

logs from personal, non-Board-issued email accounts." (Emphasis added).

The court emphasized that granting Rosetti's request would impose a

substantial burden on the Board not authorized by OPRA because Board

members would have to spend considerable time, resources, and effort to obtain

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Asbury Park Press v. County of Monmouth
966 A.2d 75 (New Jersey Superior Court App Division, 2009)
Mason v. City of Hoboken
951 A.2d 1017 (Supreme Court of New Jersey, 2008)
Bent v. Township of Stafford
884 A.2d 240 (New Jersey Superior Court App Division, 2005)
Bubis v. Kassin
878 A.2d 815 (Supreme Court of New Jersey, 2005)
Paff v. DIVISION OF LAW
988 A.2d 1239 (New Jersey Superior Court App Division, 2010)
Paff v. New Jersey Dept. of Labor
920 A.2d 731 (New Jersey Superior Court App Division, 2007)
Meshinsky v. Nichols Yacht Sales, Inc.
541 A.2d 1063 (Supreme Court of New Jersey, 1988)
DiProspero v. Penn
874 A.2d 1039 (Supreme Court of New Jersey, 2005)
Rumson Estates, Inc. v. Mayor of Fair Haven
828 A.2d 317 (Supreme Court of New Jersey, 2003)
MAG v. Division of ABC
868 A.2d 1067 (New Jersey Superior Court App Division, 2005)
Burnett v. County of Gloucester
2 A.3d 1110 (New Jersey Superior Court App Division, 2010)
In the Matter of the Expungement Application of D.J.B.
83 A.3d 2 (Supreme Court of New Jersey, 2014)
North Jersey Media Group, Inc. v. Township of Lyndhurst
116 A.3d 570 (New Jersey Superior Court App Division, 2015)
City of San Jose v. Superior Court of Santa Clara Cnty.
389 P.3d 848 (California Supreme Court, 2017)
John Paff v. Galloway Township (077692) (Atlantic and Statewide)
162 A.3d 1046 (Supreme Court of New Jersey, 2017)
Nissen v. Pierce County
357 P.3d 45 (Washington Supreme Court, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Alex Rosetti v. Ramapo-Indian Hills Regional High School Board of Education, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alex-rosetti-v-ramapo-indian-hills-regional-high-school-board-of-education-njsuperctappdiv-2025.