Estevez v. New York City Police Dept.

2025 NY Slip Op 30380(U)
CourtNew York Supreme Court, New York County
DecidedJanuary 30, 2025
DocketIndex No. 151851/2023
StatusUnpublished

This text of 2025 NY Slip Op 30380(U) (Estevez v. New York City Police Dept.) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estevez v. New York City Police Dept., 2025 NY Slip Op 30380(U) (N.Y. Super. Ct. 2025).

Opinion

Estevez v New York City Police Dept. 2025 NY Slip Op 30380(U) January 30, 2025 Supreme Court, New York County Docket Number: Index No. 151851/2023 Judge: Shahabuddeen A. Ally Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. [FILED: NEW YORK COUNTY CLERK 01/31/2025 01:01 P~ INDEX NO. 151851/2023 NYSCEF DOC. NO. 44 RECEIVED NYSCEF: 01/31/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. SHAHABUDDEEN A. ALLY PART16 Justice

FRANK ESTEVEZ, INDEX NO. 151851/2023

MOTION DATE 3/27/2023 Petitioner, MOTION SEQ. NO. 001

For a Judgment Pursuant to Article 78 of the Civil Practice Law and Rules

-against- DECISION & ORDER NEW YORK CITY POLICE DEPARTMENT and CITY OF NEW YORK,

Respondents.

The following e-filed documents, listed by NYSCEF document number, were read on Mot. Seq. No. 1 to/for ARTICLE 78 (BODY OR OFFICER): 1-13, 16-38, 40-41

On July 17, 2023, the Court issued an Interim Order in this special proceeding granting the Verified Petition and Notice of Petition insofar as requiring respondents NEW YORK CITY POLICE DEPARTMENT (the "NYPD") and CITY OF NEW YORK (the "City"; and, together with the NYPD, "Respondents") to submit redacted and unredacted copies of the body-worn camera

("BWC") footage relating to Arrest ID Q2206422-L to the Court for in camera review. (NYSCEF

Doc. 41) The Court assumes familiarity with the Interim Order.

I. PROPRIETY OF REDACTIONS

On August 8, 2023, in compliance with the Interim Order, Respondents submitted the re- dacted and unredacted BWC footage. (See id. Doc. 43) The footage comprises six separate video files. The Court has reviewed the unredacted footage and now determines whether the redactions were properly applied according to the claimed exemptions under New York Public Officers Law ("POL") § 87(2).

151851/2023 Frank Estevez v. New York City Police Department et al. Page 1 of 11 Mot. Seq. Nos. 001

1 of 11 [* 1] [FILED: NEW YORK COUNTY CLERK 01/31/2025 01:01 P~ INDEX NO. 151851/2023 NYSCEF DOC. NO. 44 RECEIVED NYSCEF: 01/31/2025 A. Redactions of Video and Audio Related to the Complainant and Her Child

According to the Vaughn index that Respondents have submitted categorizing each of the redactions and the allegedly applicable exemptions, the overwhelming majority of the redactions applied across the six video files constitute blurring of the female complainant's and her child's face in the footage and removal of any audio in the footage capturing their speech. (See Affirm. of Katherine T. Obanhein in Supp. of Verified Answer, dated Mar. 20, 2023 (NYSCEF Doc. 22),

footage are based on assertions of exemptions under POL§ 87(2)(b) and (f).

As stated in the Interim Order, it is well settled that the provisions of FOIL are "to be

liberally construed and its exemptions narrowly interpreted so that the public is granted maxi- mum access to the records of government." Capital Newspapers, Div. of Hearst Corp. v. Whalen, 69 N.Y.2d 246,252 (1987). The agency relying on an exemption to deny access to a record must "ar- ticulate a particularized and specific justification" for doing so. Dilworth v. Westchester Cnty. Dep't

of Corr., 92 A.D.3d 722, 724 (2d Dep't 2012) (internal quotation marks and citation omitted). To make such a showing, evidentiary support is necessary and conclusory assertions are insufficient. Id.

POL§ 87(2)(b) provides for exemptions of records that "if disclosed would constitute an unwarranted invasion of personal privacy" under POL § 89(2), which includes, but is not limited

to:

i. disclosure of employment, medical or credit histories or personal references of applicants for employment; ii. disclosure of items involving the medical or personal records of a client or patient in a medical facility; iii. sale or release of lists of names and addresses if such lists would be used for commercial or fund-raising purposes; iv. disclosure of information of a personal nature when disclosure would result in economic or personal hardship to the subject party and such information is not relevant to the work of the agency re- questing or maintaining it; v. disclosure of information of a personal nature reported in confi- dence to an agency and not relevant to the ordinary work of such agency; vi, information of a personal nature contained in a workers' compen- sation record, except as provided by section one hundred ten-a of the workers' compensation law;

151851/2023 Frank Estevez v. New York City Police Department et al. Page 2 of 11 Mot. Seq.Nos.001

2 of 11 [* 2] [FILED: NEW YORK COUNTY CLERK 01/31/2025 01:01 P~ INDEX NO. 151851/2023 NYSCEF DOC. NO. 44 RECEIVED NYSCEF: 01/31/2025 vii, disclosure of electronic contact information, such as an e-mail ad- dress or a social network username, that has been collected from a taxpayer under section one hundred four of the real property tax law; or viii. disclosure of law enforcement arrest or booking photographs of an individual, unless public release of such photographs will serve a specific law enforcement purpose and disclosure is not precluded by any state or federal laws.

POL § 89(2)(b). Absent specific reference to one of the above categories, however, a Court as- sessing the applicability of this exemption must "balance the privacy interests at stake against the public interest in disclosure of information." Regenhard v. City of NY., 102 A.D.3d 612, 613 (1st Dep't 2013).

Initially, while the NYPD has cited numerous cases in support of its position that the re-

daction of the complainant's and her child's faces are proper under POL§ 87(2)(b), the vast ma- jority of those cases involve the potential revelation of names, addresses, or other specific written information that could lead to the identification of the individuals in question. Only one of those

cases actually involves the blurring of faces in video footage, and the relevant decision in that case is unpublished. In Spectrum News NYl v. New York City Police Department, the petitioner sought the release of numerous videos involving NYPD officers' interactions with the public, in-

cluding individuals reporting crimes to officers and individuals in the midst of arrest by officers. See Sup. Ct., N.Y. Cnty., Jan. 29, 2019, Freed, J. Index. No. 150305/2016, NYSCEF Doc. 114 at 3-23. In an Interim Decision issued on January 29, 2019, the court resolved a number of the parties'

disputes concerning the propriety of the redactions that the NYPD applied to certain of the videos pursuant to exemptions under POL § 87(2). See id. at 25-33. Regarding whether the NYPD' s blur- ring of individuals' faces in the videos pursuant to the privacy exemption under POL§ 87(2)(b)

was proper, the court held:

It can hardly be doubted considering the extent of current technology that a person's face is as identifying as his or her name and address. Facial recognition technology has made it possible for people to open their phones with a camera and for computer software to identify individuals. Further, the ease with which videos can now be shared through social me- dia has allowed those captured in so-called viral videos to be identified within a matter of hours or even minutes. The Court must also keep in mind that the members of the public who are captured in the videos did not consent to have their images captured by the police cameras.

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

Related

New York Times Co. v. Regenhard
829 N.E.2d 266 (New York Court of Appeals, 2005)
Capital Newspapers v. Whalen
505 N.E.2d 932 (New York Court of Appeals, 1987)
Bellamy v. New York City Police Department
87 A.D.3d 874 (Appellate Division of the Supreme Court of New York, 2011)
Hossain v. Kurzynowski
92 A.D.3d 722 (Appellate Division of the Supreme Court of New York, 2012)
Johnson v. New York City Police Department
257 A.D.2d 343 (Appellate Division of the Supreme Court of New York, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
2025 NY Slip Op 30380(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/estevez-v-new-york-city-police-dept-nysupctnewyork-2025.