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Otherwise Exempt NY Correctional Incident Reports, Related Documents Ordered Disclosed With Appropriate Redaction

New York State prisoner Abdul Beyah appealed a court's 2002 affirmation of the New York Department of Correctional Services (DOCS) refusal to produce incident reports from the Auburn Correctional Facility (ACF). The court ordered the information with appropriate redaction.

Following the alleged 1999 incident in which Beyah was injured by ACF staff, the documents were requested under the state's Freedom of Information Law. The request was denied and an administrative appeal failed. Beyah's attorneys filed an action to compel. The DOCS argued that some of the information was exempt as medical histories due to guard sustained injuries, some as personnel records, and others as non-routine criminal investigation techniques. The court denied the action and the attorney's fees. Beyah appealed.

On appeal and after an in camera inspection, the court ordered the requested document with the appropriate redaction but affirmed the denial of attorney's fees. See: Beyah v. Goord, 309 A.D.2d 1049, 766 N.Y.S.2d 222 (N.Y. App. 2003).

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Related legal case

Beyah v. Goord