Canty v. Office of Counsel
The petitioner, an inmate at Southport Correctional Facility, initiated a CPLR article 78 proceeding to challenge the denial of his Freedom of Information Law (FOIL) request. He sought accident reports of correction officers injured during a riot at Auburn Correctional Facility. The respondent, Department of Correctional Services, argued that the documents were exempt under privacy and confidentiality statutes, including Public Officers Law and Civil Rights Law. The court granted the petition in part, ordering the production of the upper portion of the accident/injury reports for Correction Officers Peter Kuc, Richard Knight, and Jeffrey W. Claflin, with specific redactions for personal information. However, the court denied access to the lower, medical portion of these reports and workers' compensation benefit election forms, deeming them exempt under various statutes including HIPAA and Public Health Law.