VIA EMAIL ONLY

February 19, 2026                

Mr. Thomas Reddy

Marc DeSisto, Esq.

Legal Counsel, Cranston Police Department

Dear Mr. Reddy and Attorney DeSisto:

We have completed our investigation into the Access to Public Records Act (“APRA”) Complaint filed by Mr. Thomas Reddy (“Complainant”) against the Cranston Police Department (“Department”). For the reasons set forth herein, we find that the Department did not violate the APRA.

The Complainant requested: “police records relating to [a specified address in] Cranston, for the years 1976 to 1980.”[1] The Department provided the Complainant with certain dispatch logs but maintained an additional responsive report that it withheld in full. The Complainant objects to the Department’s full denial of “report #78-16990-OF” pursuant to Exemption (D)(c). He contends that three specific factors support production of the record “even in redacted form”: 1) “Historical Significance” because “[t]he report concerns events that occurred more than 45 years ago,” 2) “[r]edaction [c]apability,” and 3) the “substantial public interest in understanding patterns of police conduct and response.”

Marc DeSisto, legal counsel to the Department, submitted a substantive Response. The Department first argues that “law enforcement records involving specific identifiable private citizens implicate personal privacy interests, particularly when no arrest takes place,” as was the case here.[2] The Department additionally argues that “the privacy interests of the subjects in [the] report outweighed the public’s interest in … disclosure,” particularly given the fact that, although the request seeks records from the late 70s, “privacy interests of the descendants and family members of the subjects in the report” must be considered. Finally, the Department notes that the manner in which the request is worded is such that the Complainant “or an individual to whom he divulges the address could easily deduce the identities of those involved” in any “incidents that occurred” at the specified address. The Department further notes that it provided the Complainant with “dispatch logs” relative to the specifications of the request and that this record provides an understanding “at least to some extent, [of] the nature of the incident and police response to the address.” The Department provided this Office with a copy of the single withheld record for an in camera review.

When a law enforcement entity investigates a member of the public and determines that no arrest is warranted, records related to that investigation implicate privacy interests. See, e.g., Fund for Constitutional Government  v. National Archives and Records Service, 656 F.2d 856, 864 (D.C. Cir. 1981)[3] (“There can be no clearer example of an unwarranted invasion of personal privacy than to release to the public that another individual was the subject of an FBI investigation.”); see also American Civil Liberties Union v. Department of Justice, 655 F.3d 1, 7 n.8 (D.C. Cir. 2011) (“[D]isclosure of records revealing that an individual was involved or mentioned in a law enforcement investigation implicates a significant privacy interest,” particularly where the individual was never charged or convicted). Additionally, private individuals who encounter the police to report crimes or for other reasons unrelated to being arrested have a privacy interest in reports containing their personal information and documenting those encounters. See Lyssikatos v. Narragansett Police Department, PR 21-12 (finding that third-party complainants have a privacy interest in their personal information in police reports).

This Office has repeatedly recognized that when applying the balancing test to records pertaining to incidents where no arrest occurred, it is imperative that the public body conduct a thoughtful case-by-case analysis, but oftentimes, the privacy interests may be especially heightened and the scales could accordingly tip in favor of nondisclosure. See Jenkins and Langer v. Narragansett Police Department, PR 20-35; Mercurio v. Cranston Police Department, PR 20-31; Harper v. Portsmouth Police Department, PR 19-15. This Office has also noted that there are heightened privacy considerations where a requester seeks law enforcement records “pertaining to a specific individual or incident where redaction was unlikely to be able to effectively address privacy concerns.” See Milkovits v. Cranston Police Department, PR 24-09.

Here, the instant Complaint is premised on the Department’s denial of a single police report (“#78-16990-OF”) connected to an identifiable street address and reflective of a specific timeframe (“January 1, 1976, through December 31, 1980”). The Complainant does not dispute the Department’s assertion that through this framing of the request, the Complainant could “easily deduce the identities of those involved” in the police activity reflected in report “#78-16900-OF,” even if the report was redacted. Additionally, it is undisputed that no arrest took place. Our in camera review of the withheld record confirms that it implicates privacy interests in that it identifies by name two private members of the public (with reference to their personally-identifiable information), mentions other third parties, and discusses a sensitive, private matter. As such, the privacy interests of the individuals identified in that report are clearly implicated.[4] See Gagliano v. Narragansett Police Department, PR 21-14 (finding no APRA violation where individual privacy interests were implicated because the requester sought records “about a particular incident” where “specific identifying information for several private citizens” was provided).

We must next determine whether the public interest in the disclosure of the report outweighs the clearly implicated privacy interests as set forth above. See Dept. of Justice v. Reporters Comm. For Freedom of the Press, 489 U.S. 749, 772 (1989) (“[W]hether disclosure of a private document . . . is warranted must turn on the nature of the requested document and its relationship to ‘the basic purpose … to open agency action to the light of public scrutiny.’”); Farinelli v. City of Pawtucket, PR 23-39 (“The touchstone concerning whether public disclosure of a record maintained by the government outweighs an individual’s privacy is whether the records concern official information about the government agency or sheds light on the conduct of government.”).

Here, the Complainant argues that there is “substantial public interest” in production of the report because it could assist in “understanding patterns of conduct and response.” We find this argument to be unavailing. It bears repeating that the request at issue seeks a single police record clearly associated with a specific street address and a specific timeframe. The Complainant does not explain how disclosure of this single report about a single incident from decades ago would meaningfully shed light on “patterns of conduct and response.” Further, our in camera review of the responsive report does not suggest that disclosure of the responsive report would meaningfully advance the public interest, which in the APRA context means shedding light on government. Consequently, the public interest does not outweigh the evident privacy interests addressed above. See Holmes v. South Kingstown Police Department, PR 25-38 (finding that “the specific nature of the requested records, which pertain[ed] to two singular incidents and which [were] highly sensitive … would not substantially serve the identified public interest”).

For this same reason, the Complainant’s argument that the record could be provided with “appropriate redactions” fails. As we noted in Wambugu v. City of Pawtucket, PR 25-16:

“Redactions may be more likely to effectively address privacy concerns where a requester seeks a large number of incident reports or seeks reports not related to specific or identifiable individuals. See Yolken, et al. v. City of Providence, PR 21-09 (finding that redaction of personally identifying information sufficiently protected privacy interests when the requester sought ‘a large number of incident reports related to overdoses (approximately 200)’).”

Because Complainant is not seeking “a large number of incident reports” or “reports not related to specific or identifiable individual,” redaction here would not effectively address the privacy concerns. See Zimmerman v. Rhode Island State Police, PR 25-30 (“the specific nature of the request makes redaction impractical.”).

As such, we find that the Department’s withholding of the responsive offense report in its entirety was permissible under Exemption (D)(c), and we find no violation.