Key Corp. v. Greenville Public Library
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The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Plaintiff, Key Corporation, holding that Defendant, Greenville Public Library, was not entitled to relief on its two claims of error.
Plaintiff filed a complaint seeing a declaratory judgment that Defendant violated the Access to Public Records Act (the APRA), R.I. Gen. Laws 1956 chapter 2 of title 38, and seeking an order directing Defendant to produce requested records pursuant to the APRA. Plaintiff argued that Defendant was a quasi-municipal corporation that received seventy percent of its funding from the Town of Smithfield and therefore was a "public body" or "agency" as defined by the APRA. The hearing justice determined that Defendant was a public body subject to the APRA and accordingly granted Plaintiff's motion for partial summary judgment. The Supreme Court affirmed, holding that the hearing justice (1) did not err in determining that Defendant was a public body; and (2) acted within his discretion in awarding fees and costs.
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