A New Jersey court recently ruled on two appeals involving the City of Paterson and its compliance with the Open Public Records Act (OPRA). The court's decision affects how public records are accessed and the potential for attorney fees in cases where access is denied. This ruling is significant for residents seeking transparency from their local government.

The appeals were filed by Ayana Miller and Jerry Labozzo against the City of Paterson. Both plaintiffs claimed that the city failed to respond adequately to their OPRA requests. The court's ruling on October 27, 2026, vacated the lower court's orders and sent the cases back for further review.

Labozzo's appeal stemmed from a request he made in January 2025 for correspondence related to him from Paterson's former mayor and other officials. After agreeing on search terms, Labozzo alleged that the city did not respond within the required timeframe. This prompted him to file a complaint. Meanwhile, Miller's case arose from her request for video footage related to a motor vehicle accident in which she was injured. Despite submitting her request in December 2024, Miller claimed the city did not respond adequately, leading her to file a complaint as well.

Both cases were consolidated for the court's opinion. On August 14, 2025, the trial court ordered the City of Paterson to comply with Labozzo's OPRA request but denied his requests for a declaration of violation, attorney's fees, and civil penalties. Similarly, Miller's request for a declaration of violation and attorney's fees was also denied. Both plaintiffs subsequently appealed the trial court's decisions.

The court ruled that the trial court did not provide sufficient findings or reasoning for its decisions. It stated, "the court shall make appropriate findings of fact and conclusions of law regarding whether plaintiffs were prevailing parties, as well as the issues of counsel fees and civil penalties." The judges emphasized that the trial court must clarify whether the City of Paterson violated OPRA and whether the plaintiffs are entitled to any fees or penalties.

This ruling has implications for public records access in New Jersey. It reinforces the importance of transparency in government and the necessity for courts to provide clear reasoning in their decisions regarding public records requests. The court's decision also highlights the potential for attorney's fees to be awarded in cases where access to public records is improperly denied.

Going forward, the remand means that the lower court will need to reassess the cases of Labozzo and Miller. The court is expected to provide more detailed findings regarding the city's compliance with OPRA and whether the plaintiffs are entitled to attorney's fees or civil penalties. This decision could set a precedent for how similar cases are handled in the future.

As for the next steps, both cases will return to the lower court for further proceedings. The court will need to determine the specifics of the OPRA violations and the appropriate remedies for the plaintiffs. It remains to be seen whether the City of Paterson will appeal this ruling or if there are any related cases pending.