New York Law Review

Tag: Matter of Johnson Newspaper Corp. v. Stainkamp

  • Matter of Johnson Newspaper Corp. v. Stainkamp, 61 N.Y.2d 958 (1984): Access to Public Records and CPL 160.50 Sealing

    Matter of Johnson Newspaper Corp. v. Stainkamp, 61 N.Y.2d 958 (1984)

    CPL 160.50 mandates that records sealed pursuant to its provisions are exempt from public inspection, even under freedom of information laws.

    Summary

    This case concerns a newspaper’s attempt to access police records. The Court of Appeals modified the Appellate Division’s order, holding that while the newspaper was generally entitled to the requested records, any records sealed under CPL 160.50 must be excluded from inspection. The Court emphasized that CPL 160.50 protects the rights of third parties and overrides general freedom of information principles. The Court explicitly refrained from ruling on the applicability of CPL 160.50 to traffic tickets or the validity of any specific sealing orders.

    Facts

    Johnson Newspaper Corp. sought access to certain police records from the City of Watertown Police Department. The specific nature of the records wasn’t detailed, but the request was broad enough to encompass the records eventually described in the Appellate Division’s order.

    Procedural History

    The case originated in a lower court, where Johnson Newspaper Corp. sought access to the records. The Appellate Division granted relief to the newspaper. The City of Watertown Police Department appealed to the New York Court of Appeals. The Court of Appeals modified the Appellate Division’s order to exempt records sealed under CPL 160.50 and affirmed the order as modified.

    Issue(s)

    Whether records sealed pursuant to CPL 160.50 are subject to public inspection under freedom of information laws.

    Holding

    Yes, because CPL 160.50 creates an exception to general freedom of information principles, protecting the rights of individuals whose records have been sealed under that statute.

    Court’s Reasoning

    The Court of Appeals agreed with the Appellate Division’s decision to grant the newspaper access to the records, but emphasized the importance of CPL 160.50. The Court stated that the appellant raised contentions under CPL 160.50 for the first time in the Court of Appeals, which would normally preclude consideration of those arguments. However, because the rights of third parties were implicated, the Court modified the order to exempt sealed records. The Court referenced Public Officers Law § 87(2)(a), which allows agencies to deny access to records that “are specifically exempted from disclosure by state or federal statute.” The court emphasized it was not deciding whether CPL 160.50 applied to traffic tickets, and that the validity of any sealing orders was outside the scope of review. The Court determined that the records sought fell within the scope of the newspaper’s request, despite any potential lack of precise description. The court reasoned that the records described in the order of the Appellate Division fell well within the scope of the request, even if the request did not use the exact nomenclature for those records.