RICHARD RIVERA, LLC VS. TOWNSHIP OF BLOOMFIELD (L-7478-17, ESSEX COUNTY AND STATEWIDE)

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 9, 2020
DocketA-3338-17T1
StatusUnpublished

This text of RICHARD RIVERA, LLC VS. TOWNSHIP OF BLOOMFIELD (L-7478-17, ESSEX COUNTY AND STATEWIDE) (RICHARD RIVERA, LLC VS. TOWNSHIP OF BLOOMFIELD (L-7478-17, ESSEX COUNTY AND STATEWIDE)) 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
RICHARD RIVERA, LLC VS. TOWNSHIP OF BLOOMFIELD (L-7478-17, ESSEX COUNTY AND STATEWIDE), (N.J. Ct. App. 2020).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3338-17T1

RICHARD RIVERA, LLC,

Plaintiff-Appellant,

v.

TOWNSHIP OF BLOOMFIELD, LOUISE M. PALAGANO,1 in her official capacity as Records Custodian for the Township of Bloomfield, ESSEX COUNTY PROSECUTOR'S OFFICE, and CHERYL M. CUCINELLO, in her official capacity as Records Custodian for the Essex County Prosecutor's Office,

Defendants-Respondents. _____________________________

Argued December 18, 2019 – Decided January 9, 2020

Before Judges Mayer and Enright.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Docket No. L-7478-17.

1 Because plaintiff resolved the matter with defendants Township of Bloomfield and Louise M. Palagano, they are not participating on appeal. CJ Griffin argued the cause for appellant (Pashman Stein Walder Hayden PC, attorneys; CJ Griffin, of counsel and on the briefs).

Matthew I.W. Baker argued the cause for respondents Essex County Prosecutor's Office and Cheryl M. Cucinello (Genova Burns LLC, attorneys; Kathleen Barnett Einhorn, of counsel and on the brief; Matthew I.W. Baker, on the brief).

Jacob Schermerhorn Perskie argued the cause for amicus curiae American Civil Liberties Union of New Jersey (Fox Rothschild LLP, attorneys; Jacob Schermerhorn Perskie, of counsel and on the brief; Jeanne LoCicero and Alexander Shalom, on the brief).

PER CURIAM

Plaintiff Richard Rivera, LLC 2 appeals from a March 12, 2018 order

denying its order to show cause (OTSC) and dismissing its verified complaint.

Plaintiff sought records related to a police-involved shooting under the OPRA.

The motion judge held certain video recordings of the incident were exempt

from disclosure because they fell under the criminal investigatory records

exception to OPRA. As a result, the judge denied plaintiff's OPRA request and

attorney's fees. We reverse.

2 Plaintiff provides expert witness services regarding police practices and serves as a consultant on police matters. The company routinely files requests pursuant to the Open Public Records Act (OPRA), N.J.S.A. 47:1A-1 to -13, for records related to incidents of force by police officers, particularly incidents involving deadly shootings, and reviews dash and body camera footage of such incidents. A-3338-17T1 2 Plaintiff filed an OPRA request for government records with defendant

Township of Bloomfield (Bloomfield) and defendant Essex County Prosecutor's

Office (ECPO) pertaining to a police-involved shooting. The shooting occurred

in Bloomfield on August 18, 2017, when a knife wielding male was killed by

police officers responding to a 9-1-1 call.

Three days after the shooting, plaintiff sought OPRA information from

Bloomfield and the ECPO, including body-worn camera (BWC) footage. The

next day, the ECPO partially responded to plaintiff's OPRA request, providing

some of the information required pursuant to N.J.S.A. 47:1A-3(b). The ECPO

advised, "the investigation is active and no additional information is available

at this time." The ECPO acknowledged a full response to plaintiff's OPRA

request was due on August 30, 2017, but sought an extension of time until

September 20, 2017, "[d]ue to the nature of the request and relevant staff being

on vacation."3

In response to plaintiff's OPRA request, Bloomfield produced use of force

reports, dash camera footage, recordings of 9-1-1 calls related to the event,

information pursuant to N.J.S.A. 47:1A-3(b), and use of force training

3 Bloomfield also requested an extension of time to respond to plaintiff's OPRA request because it required approval from the ECPO to release records.

A-3338-17T1 3 certificates for the officers involved in the incident. Bloomfield denied

plaintiff's request for the BWC footage because the ECPO "[did] not believe that

the public's need for access outweigh[ed] the law enforcement interest in

maintaining confidentiality of the . . . recordings (See Attorney General Law

Enforcement Directive No. 2015-1, 11.2)." The ECPO adopted and incorporated

Bloomfield's response to plaintiff's OPRA request.4

On October 18, 2017, plaintiff filed a verified complaint and OTSC

alleging OPRA violations for failure to disclose the BWC footage and requesting

attorney's fees. On October 24, 2017, the trial court entered the OTSC and

scheduled a return date. Two months later, the ECPO filed opposition to

plaintiff's OTSC and submitted a short certification from a Special Deputy

Attorney General/Acting Assistant Prosecutor within the Professional Standards

Bureau of the ECPO. According to the certification, the BWC footage was

subject to an active investigation and therefore exempt from disclosure under

OPRA.

4 Neither Bloomfield nor the ECPO provided the information within twenty- four hours of plaintiff's OPRA request in accordance with N.J.S.A. 47:1A-3(b) (requiring release of information pursuant to an OPRA request "within 24 hours or as soon as practicable"). A-3338-17T1 4 On January 19, 2018, the trial court heard the parties' arguments. The

judge ruled the BWC footage was exempt from OPRA disclosure because the

footage was a criminal investigatory record and "not required by law to be made,

maintained or kept pursuant to N.J.S.A. 47:1A-1.1." The judge further found

the criminal investigation was ongoing and the public's need for access to the

footage was "not outweighed by the [p]rosecutor's interest . . . in keeping this

confidential." He found "no law that requires [BWC] recordings to be made or

maintained" and therefore the ECPO "did not violate OPRA because they did

not have to turn over the body footage." The judge also held the delay in

responding to plaintiff's OPRA request was "de minimis" and not in violation of

OPRA. Because the judge denied plaintiff's OPRA request in its entirety, he

determined plaintiff was not entitled to attorney's fees.

On appeal, plaintiff argues the judge erred in determining the BWC

footage was exempt from OPRA disclosure because the videos were criminal

investigatory records. Plaintiff also contends the judge mistakenly concluded

the ECPO's delay in responding to the OPRA request was "de minimis."

Plaintiff additionally claims the judge erred in denying its request for attorney's

fees.

A-3338-17T1 5 We exercise de novo review of a trial court's legal conclusions concerning

access to public records under OPRA. Drinker Biddle & Reath, LLP v. N.J.

Dep't of Law & Pub. Safety, 421 N.J. Super. 489, 497 (App. Div. 2011).

"[D]eterminations about the applicability of OPRA and its exemptions are legal

conclusions" reviewable de novo. Carter v. Doe (In re N.J. Firemen's Ass'n

Obligation), 230 N.J. 258, 273-74 (2017) (citing O'Shea v. Twp. of W. Milford,

410 N.J. Super. 371, 379 (App. Div. 2009)).

"Any analysis of OPRA must begin with the recognition that the

Legislature created OPRA intending to make governmental records 'readily

accessible' to the state's citizens 'with certain exceptions[] for the protection of

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

Related

Mason v. City of Hoboken
951 A.2d 1017 (Supreme Court of New Jersey, 2008)
O'Shea v. Township of West Milford
982 A.2d 459 (New Jersey Superior Court App Division, 2009)
Drinker Biddle v. Dept. of Law
24 A.3d 829 (New Jersey Superior Court App Division, 2011)
Patricia Gilleran v. Township of Bloomfield(076114)
149 A.3d 800 (Supreme Court of New Jersey, 2016)
Courier News v. Hunterdon County Prosecutor's Office
817 A.2d 1017 (New Jersey Superior Court App Division, 2003)
New Jersey Firemen's Ass'n v. Doe
166 A.3d 1125 (Supreme Court of New Jersey, 2017)
Paff v. Ocean Cnty. Prosecutor's Office
192 A.3d 975 (Supreme Court of New Jersey, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
RICHARD RIVERA, LLC VS. TOWNSHIP OF BLOOMFIELD (L-7478-17, ESSEX COUNTY AND STATEWIDE), Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-rivera-llc-vs-township-of-bloomfield-l-7478-17-essex-county-and-njsuperctappdiv-2020.