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New York Police IA Records in Camera Inspection Improperly Denied

The New York Supreme Court, Appellate Division reversed a lower court's denial of in camera inspection of police internal affairs records in a wrongful death action.

Christine Cea and others brought a state court wrongful death action against the Suffolk County Police Department (SCPD).

On August 15, 2012, the Suffolk County Supreme Court issued an order denying Cea's motion to compel production and in camera inspection of certain records of the SCPD Internal Affairs Bureau pursuant to Civil Rights Law § 50-a.

The New York Supreme Court, Appellate Division reversed. Citing Blanco v. County of Suffolk, 51 AD3d 700, 701-02 and Civil Rights Law §50-a, the court found that "plaintiffs established a factual predicate for obtaining access to the subject records . . . which might contain information that is relevant and material to the underlying incident." As such, "the Supreme Court should have granted plaintiffs' motion, conducted an in camera inspection of the records, and directed the disclosure of all relevant and material information contained therein," the court held. See: Cea v. Zimmerman, 2013 NY Slip Op 07007 (NY App Div., 2nd Dept 2013).

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Related legal case

Cea v. Zimmerman