Gannett Co. v. Rochester City School District

OPINION OF THE COURT

Robert J. Lunn, J.

These two CPLR article 78 proceedings involve the identical legal issue. They have been joined upon the court’s own motion for purposes of decision. Both cases assigned to this IAS Part present a novel question of law. The issue is whether a school district’s internal audit report regarding a particular high school within that district is subject to public disclosure under the New York Freedom of Information Law (Public Officers Law § 84 et seq. [hereafter FOIL]).

The facts are essentially not in dispute and may be briefly summarized. The internal audit…