VIA EMAIL ONLY

January 28, 2026

Ms. Ca’lea Daniel

Mr. Donte L. Holman

Benjamin Copple, Esquire

Legal Counsel, Rhode Island Department of Children, Youth and Families

Dear Ms. Daniel, Mr. Holman, and Attorney Copple:

We have completed an investigation into the Access to Public Records Act (“APRA”) Complaints filed by Ms. Ca’lea Daniel (“Complainant 1”) and Mr. Donte L. Holman (“Complainant 2”) against the Rhode Island Department of Children, Youth and Families (“DCYF”). We consolidate these Complaints and address them in a single finding, as they present substantively similar issues and both involve the DCYF. For the reasons set forth herein, we find that the DCYF did not violate the APRA.

“de-identified administrative hotline data—specifically dates, times, allegation categories, screening decisions, investigator/unit assignment, and final disposition codes for intakes concerning [a specific household] from January 2022 through October 2025.”[1]

Both requests were denied by the DCYF in full pursuant to Exemptions (C) and (S). Complainant 1 challenges the DCYF’s denial. She contends that the full denial was inappropriate in that the DCYF failed to “distinguish between requests for confidential case files [and] requests for administrative, non-identifiable data under [the] APRA.”

Attorney Benjamin Copple submitted substantive responses as to both Complaints. In response to Complainant 1’s Complaint, the DCYF reiterates and expands upon the applicability of Exemptions (C) and (S) and R.I. Gen Laws 42-72-8[2]  to the subject records, (assuming such records exist).[3] The DCYF further states that Complainant 1’s requests were framed in a manner applicable to “identified children and/or … [a] child” and that multiple federal laws prevent disclosure of such records if they exist. Finally, the DCYF submits that these records would not be reasonably segregable due to state and federal laws rendering such records fully confidential.

We acknowledge Complainant 1’s Rebuttal. Complainant 1 notes her personal interest in the records which she contends distinguishes her from being a “general public requester.” She also clarifies that her October 15, 2025 request sought “administrative metadata only.”

• Complainant 2’s August 25, 2025 Complaint

Complainant 2 submitted his initial APRA request on June 27, 2025. As to four identifiable individuals,[4] he sought: “all DCYF records related to … [those individuals] from December 1, 2013, to the present date (June 27, 2025) … [including but not limited to]: Case notes, [i]nvestigation reports, [s]afety plans, [p]lacement records, [s]ervice referrals, [c]ommunications between DCYF staff and any external agencies.” The DCYF similarly denied this request in full, and Complainant 2’s August 25, 2025 Complaint followed. Complainant 2 argues that the DCYF’s full denial, as opposed to producing “segregated [or] redacted versions,” violated the APRA. He additionally challenges the DCYF’s use of a Glomar-type response (i.e., declining to confirm whether responsive records exist) in the context of his request.

The DCYF’s substantive Response closely mirrored its Response to Complainant 1’s Complaint. The DCYF argues that the subject records in this instance are also non-public pursuant to Exemptions (C) and (S) and “state and federal confidentiality laws,”[5] as well as R.I. Gen Laws 42-72-8. See supra. Assuming such records exist, the DCYF argues that they are “confidential by law,” with no reasonably segregable portion available for public disclosure.

 We acknowledge Complainant 2’s Rebuttal.  Like Complainant 1, Complainant 2 highlights his “[p]ersonal [s]take” in records he is seeking.

Here, as to Complainant 1’s Complaint, we find that both requests were lawfully denied in full. In Pontarelli v. Department of Children, Youth and Families, PR 23-12, the Complainant sought Family Court records related to the placement of children in a DCYF residential treatment facility. This Office found that the DCYF properly withheld the records in full. Importantly, we noted that the “DCYF cite[d] to numerous state and federal statutes to support its position – unrebutted by the Complainant – that the request records [were] confidential and thus DCYF [was] prohibited from disclosing the same to the Complainant – and ultimately, the public – even in redacted form.” We found that the Complainant in that instance did not “contest the DCYF’s argument that the types of records sought [fell] within the ambit of [the cited federal and state statutes].” As in PR 23-12, the DCYF again cites to multiple state and federal statutes to support its position, also unrebutted by the Complainant in this instance, that the DCYF is legally precluded from disclosing the requested records to Complainant 1, either in full or in part.[6] The uncontested applicability of these statutes supports the lawfulness of the DCYF’s denial.

Complainant 1’s second request, based on the foregoing, was also properly denied. It is the requester’s responsibility to properly frame APRA requests and the request as worded specifically sought “administrative hotline data” specific to a particular household. The phrasing of this request, such that it was directly associated with a specific person and identified a specific property and a readily identifiable juvenile, further underscores the non-public nature of such records, should any exist. See Pawtucket Teachers Alliance v. Brady, 556 A.2d 556, 559 (R.I. 1989) (“[T]he report at issue in the present case specifically relates to the job performance of a single readily identifiable individual. Even if all references to proper names were deleted, the principal’s identity would still be abundantly clear from the entire context of the report.”); see also Almada v. Rhode Island State Police, PR 25-70 (finding the RISP’s full denial of video footage to be appropriate, in part, because the request “related to a specific individual and incident”).

Accordingly, we find that the DCYF did not violate the APRA through its full denial pursuant to the cited exemptions.[7] See also Pontarelli v. DCYF, PR 24-02 (finding that the DCYF properly redacted certain information in DCFY petitions pursuant to “a litany of state and federal laws,” the applicability of which the Complainant did “not contest”)[8]. We also find DCYF’s use of a Glomar response to be appropriate given that even acknowledging the existence of responsive records would reveal confidential information. See Teper v. Providence Police Department, PR 20-64 (finding a Glomar response by the Department to be appropriate with respect to possible reports or investigation records attributable to a specific private citizen, as doing so would itself implicate the individual’s privacy interests).

By the same reasoning discussed supra, Complainant 2’s request was properly denied in full. Like Complainant 1’s request, Complainant 2 sought DCYF records directly associated with specific individuals.[9] He also did not contest the applicability of the various confidentiality laws to the records he requested.

Complainant 2 also raises the issue of his personal connection to any responsive records and that such a connection supersedes the confidentiality statutes invoked by the DCYF. As we have frequently observed, a personal connection to the requested records is of no consequence to our inquiry under the APRA. See Walters v. Department of Public Safety, PR 11-39 (“Under the APRA you have no greater right to access the requested records than any member of the general public, regardless of whether you are the subject of the [requested material].”). A determination by this Office that a particular document is a public record allows any member of the public to access or inspect that record, regardless of whether that person is an interested party. See McQuade v. Rhode Island State Police, PR 13-03 (“Once a record is made public to one person under the APRA, that record is made public to all.”). Our finding is limited to the APRA and we make no determination regarding whether either Complainant may have access to these records by other means. [10]

Finally, to be sure, R.I. Gen. Laws § 38-2-3(b) provides that, “[a]ny reasonably segregable portion of a public record excluded by § 38-2-2(4) shall be available for public inspection after the deletion of the information which is the basis of the exclusion.” Although both Complainants requested records in redacted form, the relevant statutes, as discussed above, require the records to be non-public in full and without exception. See Pontarelli v. Department of Children, Youth and Families, PR 23-12. Accordingly, we find no violation.