Gonen v. New York City Police Dept.

2024 NY Slip Op 30371(U)
New York Supreme Court, New York County·Decided January 31, 2024·Unpublished

Opinion

Gonen v New York City Police Dept. 2024 NY Slip Op 30371(U) January 31, 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. 33 RECEIVED NYSCEF: 01/31/2024

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 01/30/2024 Petitioners, MOTION SEQ. NO. 001 002 -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- 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 30 were read on this motion to/for ARTICLE 78 FOIL .

The following e-filed documents, listed by NYSCEF document number (Motion 002) 25, 26, 27, 28, 29 were read on this motion to/for CONFERENCE .

Motion Sequence Numbers 001 and 002 are consolidated for disposition. Respondent’s

cross-motion (MS001) to dismiss the petition, which seeks records pursuant to a Freedom of

Information Law (“FOIL”) request, is denied. Petitioners’ motion (MS002) for a status

conference is denied.

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

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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.

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.

Respondent denied petitioners’ FOIL request “on the basis of Public Officers Law

Section 87(2)(b) as such information, if disclosed, would constitute an unwarranted invasion of

personal privacy” (NYSCEF Doc. No. 4). Respondent then denied petitioners’ appeal and noted

that “the records responsive to your request are specifically exempted by state or federal statute

[§87(2)(a)] in that they have been SEALED pursuant to New York Criminal Procedure Law

§160.50” (NYSCEF Doc. No. 6). Respondent also insisted that all associated records are exempt

from disclosure and releasing these records would interfere with a law enforcement investigation

(the internal investigation) (id.).

Respondent cross-moves to dismiss the petition. It acknowledges that it found a

responsive record—the entire investigation file, which consists of a four-page report and two

attachments. The first attachment is an eight-minute, forty-four second audio recording and the

second is a two-page 911 report. It claims that these records are barred from release because

they are sealed under CPL 160.50 and due to privacy concerns.

Respondent argues that the specific IAB case number requested by petitioners concerns

the investigation into the former police officer and so all of the details relate to an arrest that has

now been sealed. It insists that contrary to petitioners’ arguments, this IAB file does not relate to

the allege misconduct of the police chief.

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In reply, petitioners argue that CPLR 160.50 does not apply in FOIL proceedings and is

only relevant to a criminal action or proceeding. They argue it has no relevance in a disciplinary

action involving a police officer. Petitioners blame respondent for not seeking clarification about

the scope of the request or notifying petitioners about its concerns.

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’s central focus in this opinion is the interaction between CPL 160.50 and

FOIL. Respondent argues in support of its cross-motion to dismiss that this criminal statute—

which provides that certain records are sealed upon the termination of a criminal action in favor

of the accused—justifies its denial of the FOIL request. However, respondent did not cite a

single case that holds that CPL 160.50 can be used to shield an entire IAB file from a FOIL

request. There is no question that the IAB file in question relates to the voided arrest of a former

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officer, but respondent did not meet its burden on a motion to dismiss to demonstrate that the

reach of this statute applies to a file created for an internal investigation within the police

department.

“In sealing the records of a prosecution that terminated in favor of the accused, the instant

statute serves the laudable goal of insuring that one who is charged but not convicted of an

offense suffers no stigma as a result of his having once been the object of an unsustained

accusation” (William C. Donnino, Prac Commentaries, CPL 160.50). “CPL 160.50 does not

define what constitutes an official record relating to an arrest or prosecution, and the Court of

Appeals has held that bright line rules are not wholly appropriate in this area” (New York Times

Co. v Dist. Attorney of Kings County, 179 AD3d 115, 123, 111 NYS3d 691 [2d Dept 2019]

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