Greim v. Pa. State Police Off. of Open Recs., 2025 Pa. Commw. LEXIS 20
(Pa. Commonwealth Court, January 17, 2025)(Leavitt, J.)
This case involves requests for information concerning a police officer. The Court standard of review of a final determination of the OOR is de novo. There is no deferens required to the OOR. In addition the Court is entitled to the broadest scope of review. The Court may substitute its own findings of fact for those of the OOR. The courts have discretion to conduct a hearing, remand to OOR or except additional evidence. Section 703 of RTKL requires written request to identify or describe records with sufficient evidence specificity. The case law is reviewed. Failure to identify a finid timeframe will not render and otherwise sufficiently specific request overbroad. On the other hand an extremely short timeframe will not rescue and otherwise overbroad request except for the most extraordinary circumstances. This case is very good in discussing all the cases concerning specificity. Here the Court found the request sufficiently specific. The subject matter of the request was limited by fourteen search terms. The failure by OOR to provide the records was reversed.