Washington Post Co. v. New York State Insurance Department

OPINION OF THE COURT

Chief Judge Cooke.

The minutes of insurance company meetings that are given by the companies to the New York State Insurance Department for its examination constitute “records” within the meaning of the New York Freedom of Information Law (FOIL). Consequently, they are subject to public review under FOIL unless it is established that the documents are, in whole or in part, subject to a statutory exemption.

Under New York’s regulatory system, the affairs of domestic insurance companies are subject to examination by the respondent State Insurance Department (see Insurance Law,…