William Grey Law Off. PLLC v. City of New York

2025 NY Slip Op 30939(U)
CourtNew York Supreme Court, New York County
DecidedMarch 24, 2025
DocketIndex No. 159412/2024
StatusUnpublished

This text of 2025 NY Slip Op 30939(U) (William Grey Law Off. PLLC v. City of New York) 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
William Grey Law Off. PLLC v. City of New York, 2025 NY Slip Op 30939(U) (N.Y. Super. Ct. 2025).

Opinion

William Grey Law Off. PLLC v City of New York 2025 NY Slip Op 30939(U) March 24, 2025 Supreme Court, New York County Docket Number: Index No. 159412/2024 Judge: Lyle E. Frank 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. 159412/2024 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 03/24/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. LYLE E. FRANK PART 11M Justice ---------------------------------------------------------------------------------X INDEX NO. 159412/2024 WILLIAM GREY LAW OFFICE PLLC MOTION DATE 10/09/2024 Petitioner, MOTION SEQ. NO. 001 -v- THE CITY OF NEW YORK S/H/A THE NEW YORK CITY DECISION + ORDER ON DEPARTMENT OF PROBATION, MOTION Respondent. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 12, 16, 17, 18, 19, 27, 28, 29, 30, 31, 33 were read on this motion to/for ARTICLE 78 (BODY OR OFFICER) .

Upon the foregoing documents, the petition is remanded for Respondent to provide a

privilege log to Petitioner, and Petitioner is granted attorneys’ fees.

Background

In June of 2024, the William Grey Law Office PLLC (“Petitioner”) made a FOIL request

to the New York City Department of Probation (“Respondent”) regarding medical exams for

individuals who had passed the Probation Officer Exam. The FOIL request had six categories of

documents. Two of them (the third and fourth categories) were denied by Respondent, citing the

inter-agency exemption to FOIL. Respondents denied being in possession of the fifth category of

documents and granted the other three requested categories. The two categories that were denied

requested 1) all written and electronic communications between employees of the New York

City Department of Probation and the New York City Police Department concerning the job

duties and responsibilities or essential requisites of the job for the title Probation Officer from

October 5, 2022 to present; and 2) a similar set of communications between the two agencies, but

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concerning how to conduct the medical review of persons who were being reviewed for

employment pursuant to a specific Probation Officer exam number.

Petitioner then appealed the two denials and requested a certification for the search on the

fifth category. Respondent’s determination on the appeal upheld all three denials, and did not

provide a certification on the fifth category. Petitioner brought the present timely Article 78

proceeding contesting that final determination, seeking a declaration that Respondent had acted

unlawfully in withholding the documents and an order directing the Respondent to provide

Petitioner with immediate access to the records. Respondent has answered and opposes the

petition. Oral argument was held on March 21, 2025.

Discussion

Essentially, Petitioner argues that Respondent was required to redact the documents

responsive to the two denied requests and turn over the redacted versions. Respondent argues

that the requested docs constitute inter-agency pre-decisional advising and therefore they were

not required to produce the documents. At oral argument, the parties agreed that Respondent

would provide Petitioner with a privilege log regarding the contested documents, resolving the

petition. The main point of contention remaining is whether Petitioner would be entitled to

attorneys’ fees in this matter. For the reasons that follow, Petitioner is entitled to attorneys’ fees

because they have substantially prevailed, and Respondent failed to articulate a reasonable basis

for withholding the documents in question.

Standard of Review

In an Article 78 proceeding, a court “may assess, against such agency involved,

reasonable attorney’s fees and other litigation costs reasonably incurred by such person in any

case [when] such person has substantially prevailed, and when the agency failed to respond to a

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request or appeal within the statutory time.” NY Pub. Off. Law § 89(4)(c)(i). But when a

petitioner substantially prevails and “the court finds that the agency had no reasonable basis for

denying access”, the award of attorney’s fees and costs is mandatory. NY Pub. Off. Law

§ 89(4)(c)(ii).

Petitioner Substantially Prevailed

As a threshold issue, a petitioner must have substantially prevailed in order to be awarded

attorneys’ fees and costs under either prong of Section 89(4)(c). The Court of Appeals has held

that even when an agency’s redactions of provided documents is upheld as appropriate, a

petitioner is considered to have substantially prevailed when the agency in question “made no

disclosures, redacted or otherwise, prior to petitioner’s commencement of this CPLR article 78

proceeding.” Matter of Madeiros v. New York State Educ. Dept., 30 N.Y.3d 67, 79 (2017); see

also Matter of Jaskaran v. City of New York, 210 A.D.3d 428, 428 (1st Dept. 2022) (holding that

it was undisputed that a petitioner substantially prevailed when during the pendency of an Article

78 proceeding, the requested FOIL records were produced with redactions); Matter of Dioso

Faustino Freedom of Info. Law Request v. New York City, 191 A.D.3d 504, 504 (1st Dept.

2021)(adopting a Third Department holding that the voluntariness of disclosure of FOIL

requested documents is “irrelevant to the issue of whether petitioner substantially prevailed”).

Therefore, the issue becomes whether Respondent had a reasonable basis for withholding the

redacted documents (in which case, a fee award would not be mandatory) or if they failed to

respond to the appeal within the statutory time (in which case, a fee award would be

discretionary).

Respondent Failed to Articulate a Reasonable Basis and Therefore Attorneys’ Fees are

Mandatory

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Respondent argues that their withholding of the requested documents under the inter-

agency exemption to FOIL constituted a reasonable basis. The inter-agency exception is found in

Pub. Off. Law § 87(2)(g) and exempts “inter-agency or intra-agency materials which are not (1)

statistical or factual tabulations or data; (ii) instructions to staff that affect the public; (iii) final

agency policy or determinations; (iv) external audits.” One “pertinent consideration in

determining whether the agency had a reasonable basis for denying a FOIL request is whether

the agency reasonably claimed the records were exempt from disclosure under Public Officers

Law § 87(2) although the denial may still have been reasonable even if the records are ultimately

deemed not to be exempt.” Matter of New York State Defenders Assn.

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Cite This Page — Counsel Stack

Bluebook (online)
2025 NY Slip Op 30939(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-grey-law-off-pllc-v-city-of-new-york-nysupctnewyork-2025.