Gonen v. New York City Police Depart.

2024 NY Slip Op 30835(U)
CourtNew York Supreme Court, New York County
DecidedMarch 14, 2024
StatusUnpublished

This text of 2024 NY Slip Op 30835(U) (Gonen v. New York City Police Depart.) 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
Gonen v. New York City Police Depart., 2024 NY Slip Op 30835(U) (N.Y. Super. Ct. 2024).

Opinion

Gonen v New York City Police Depart. 2024 NY Slip Op 30835(U) March 14, 2024 Supreme Court, New York County Docket Number: Index No. 159794/2023 Judge: Arlene P. Bluth 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. INDEX NO. 159794/2023 NYSCEF DOC. NO. 40 RECEIVED NYSCEF: 03/14/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. ARLENE P. BLUTH PART 14 Justice ---------------------------------------------------------------------------------X INDEX NO. 159794/2023 YOAV GONEN, THE CITY REPORT, INC. MOTION DATE Petitioners, MOTION SEQ. NO. 001 -v- NEW YORK CITY POLICE DEPARTMENT, DECISION + ORDER ON MOTION Respondent. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 1- 9, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 30, 31, 32, 34- 39 were read on this motion to/for ARTICLE 78- FOIL .

The petition to annul a decision concerning FOIL is decided as described below.

Background

This special proceeding concerns a FOIL request for a specific Internal Affairs Bureau

(“IAB”) file (NYSCEF Doc. No. 2). Petitioners observe that this IAB file relates to an incident

involving a retired police officer. They contend that this retired officer brandished a weapon at

three boys and, after he was subsequently arrested, a police chief voided that arrest. Petitioners

allege that IAB found that no misconduct was committed by this police chief but the Civilian

Complaint Review Board (“CCRB”) conducted its own investigation and recommended that the

police chief get docked up to 10 vacation days. Petitioners insist that the then-police

commissioner upheld this penalty and the police chief is currently challenging this determination

in an administrative trial.

159794/2023 GONEN, YOAV ET AL vs. NEW YORK CITY POLICE DEPARTMENT Page 1 of 5 Motion No. 001

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Petitioners observe that in 2023, the Brooklyn District Attorney’s Office released

numerous videos about the arrest of the former officer and the voiding of the arrest a few hours

later.

In a decision dated January 31, 2024, this Court denied respondent’s cross-motion to

dismiss this proceeding and directed respondent to answer (NYSCEF Doc. No. 32). The Court

noted that “Respondent’s cited justifications for not turning over the records in question do not

compel the Court to dismiss the proceeding at this stage. Its citation to a criminal procedure law

provision about sealing arrest records was not accompanied by any case law that shows it applies

to IAB files. And the issue of personal privacy is easily addressed with redactions” (id. at 5-6).

Respondent then answered and also disclosed a copy of the IAB investigation file to

petitioners (it included a four-page report with two attachments, an audio recording and a 911

report). It argues that the proceeding is now moot. It observes that it included redactions to “the

names, addresses, dates of birth, tax identification number, and phone numbers of the sealed

arrestee and witnesses.”

In reply, petitioners argue that the disclosure of this record does not moot the proceeding

because respondent has zeroed in on a specific case number and is seeking to avoid the

disclosure of other investigative records. They argue that the request, when taken in context and

under the circumstances, requires the disclosure of the entire investigative file. Petitioners blame

respondent for not helping them request the records and that it would be futile to make

petitioners file another FOIL request. They contend that respondent has improperly assumed that

the request only pertains to a single IAB case number.

159794/2023 GONEN, YOAV ET AL vs. NEW YORK CITY POLICE DEPARTMENT Page 2 of 5 Motion No. 001

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Discussion

“To promote open government and public accountability, FOIL imposes a broad duty on

government agencies to make their records available to the public. The statute is based on the

policy that the public is vested with an inherent right to know and that official secrecy is

anathematic to our form of government. Consistent with the legislative declaration in Public

Officers Law § 84, FOIL is liberally construed and its statutory exemptions narrowly interpreted.

All records are presumptively available for public inspection and copying, unless the agency

satisfies its burden of demonstrating that the material requested falls squarely within the ambit of

one of the statutory exemptions. While FOIL exemptions are to be narrowly read, they must of

course be given their natural and obvious meaning where such interpretation is consistent with

the legislative intent and with the general purpose and manifest policy underlying FOIL” (Abdur-

Rashid v New York City Police Dept., 31 NY3d 217, 224-25, 76 NYS3d 460 [2018] [internal

quotations and citation omitted]).

The Court denies the petition. It is moot now that respondent has turned over the

requested IAB file. The FOIL request at issue stated that “Under the provisions of the New York

Freedom of Information Law, Article 6 of the Public Officers Law, I am requesting a copy of the

investigative file for IAB case 2021-26524” (NYSCEF Doc. No. 15). And respondent asserts it

has now turned over this record. That satisfied respondent’s obligation under FOIL (Rattley v

New York City Police Dept., 96 NY2d 873, NYS2d 768 [2001] [noting that an agency satisfies

its obligation by certifying that it has disclosed all responsive documents]).

Petitioners’ argument that it was not really asking for a specific IAB case file is belied by

the FOIL request itself which mentions a specific IAB case number. Any reasonable

interpretation of the FOIL request yields the conclusion that respondent has turned over all

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responsive records. Petitioners’ attempt to assert that the context means that respondent should

have disclosed more records is without merit. Petitioners do not take issue with the redactions;

instead, they claim they are entitled to more records that are, essentially, closely related to the

specific record they requested.

Of course, respondent was obligated to respond only to the specific FOIL request at

issue; to claim that respondent was required to speculate as to what other records petitioners

might be interested in receiving exceeds respondent’s obligations under FOIL. A FOIL

proceeding is not a plenary action where parties can make broad discovery demands; rather, it is

a special proceeding commenced to evaluate the specific request at hand. Petitioner has received

what it requested.

Petitioners’ alternative argument, that it would be futile to make them file another FOIL

request, is also wholly without merit. Petitioners cannot insist that they need not follow the

FOIL process because they speculate that respondent will not turn over records in response to

those future requests.

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Related

Rattley v. New York City Police Department
756 N.E.2d 56 (New York Court of Appeals, 2001)
Abdur-Rashid v. N.Y.C. Police Dep't
100 N.E.3d 799 (Court for the Trial of Impeachments and Correction of Errors, 2018)

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2024 NY Slip Op 30835(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/gonen-v-new-york-city-police-depart-nysupctnewyork-2024.