John Paff v. Galloway Township (077692) (Atlantic and Statewide)

In this appeal, we address the scope of a municipality’s obligation to disclose electronically stored information in accordance with the New Jersey Open Public Records Act (OPRA), N.J.S.A. 47:1A-1 to -13.

Plaintiff John Paff filed a request with Galloway Township’s records custodian for specific information in emails sent by the Township’s Municipal Clerk and Chief of Police over a two-week period. From those emails, Paff sought only information contained within the following fields: “sender,” “recipient,” “date,” and “subject.” Paff did not request the contents of the emails.

The Township…