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20 Year Old Phoenix Police Investigation Documents Ordered Disclosed To Church

The Church of Scientology of Arizona (Church) appealed a court denial for 20 year old Phoenix Police Department (PPD) documents regarding an investigation of the Church and it's affiliates. The court reversed the denial ruling that no harm to the agency was imminent.
Approximately 22 of the sought documents were withheld by the PPD on grounds that they were "inter or intra agency communications." The Church sought disclosure in an action to compel pursuant to A.R.S. § 39 121. The court's in camera inspection determined the documents exempt from disclosure. The Church appealed and the PPD argued that disclosure would affect the efficient functioning of law enforcement agencies.

The Division One Court of Appeals of Arizona held that no specific state exemption
existed. It was held that disclosure posed no harm and that the documents were discloseable
under the federal Freedom of Information Act. The court further noted that it was reluctant
to thwart disclosure provisions for possible "self serving" governmental officials' inclinations. The dissent would have affirmed the denial to control "the free flow of information...among police agencies." See: Church of Scientology v. City of Phoenix Police. Department. 122 Ariz. 338, 594 P.2d 1034 (Ariz. App. 1979).

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Related legal case

Church of Scientology v. City of Phoenix Police. Department