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Oregon PRL Requires Disclosure of Documents Pertaining to Internal Investigations of Cop's Misconduct

May Davis, a citizen of Portland, Oregon, sued Portland police (City) in state court under state Public Records Laws (PR § L), Or. Rev. Stat. 192.420 et sec, to compel disclosure of records for an internal investigation of alleged police misconduct. The city provided some of the documents in redacted form, and the court upheld the fee charged therefore and denied Davis' request for attorney fees. Davis appealed.

On appeal, the Court of Appeals of Oregon found that, since the City hadn't released the documents within 7 days of Davis' request for them, Davis was entitled to attorney fees and didn't have to pay copy or redaction fees to the City. On that basis, the Court remanded with instructions for the trial court to grant attorney fees to Davis and order the fees she paid the City for redacting and photocopying the documents reimbursed. See: Davis v. Walker, 108 Ore.App. 128; 814 P.2d 547 (1991).

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Related legal case

Davis v. Walker