Patricia Gilleran v. the Township of Bloomfield And louise M. Palagano, 114 A.3d 780

Plaintiff Patricia Gilleran made an OPRA request for security camera recordings from a stationary camera on the rear of Bloomfield Town Hall for March 31, 2014 (7:00 a.m.–9:00 p.m.), after narrowing an initial five-day request.
The camera views the Mayor’s parking spot and the rear door and is plainly visible on the building exterior; Gilleran offered to provide a hard drive to receive the recordings in native format.
The Township denied the request under OPRA exemptions for "emergency or security information" and "security measures and surveillance techniques," supported by a certification from the Township Administrator containing general, conclusory statements about security risks.
Gilleran filed suit in the Law Division, which ordered disclosure and found the Township had not met its burden to prove an exemption; the court also awarded prevailing-party fee relief under OPRA.
On appeal, the Appellate Division affirmed, holding OPRA does not create a blanket exemption for security-camera recordings and that Bloomfield failed to make the required specific showing to withhold the footage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether security-camera recordings are categorically exempt from OPRA disclosure	Gilleran: No; OPRA presumes disclosure and a visible camera does not make contents confidential	Bloomfield: Yes; recordings are security information/measures and thus exempt	Held: No blanket exemption; agency must make a specific showing to withhold
Whether Bloomfield met its burden to show recordings would jeopardize safety or security	Gilleran: Township’s general assertions insufficient; public could observe same areas; must disclose absent specific risk	Bloomfield: Generalized certification that disclosure could reveal informants/victims or compromise security suffices	Held: Township’s conclusory certification was insufficient to meet burden
Whether OPRA required Bloomfield to review recordings and redact exempt portions before release	Gilleran: Yes; custodian must excise exempt portions per N.J.S.A. 47:1A-5(g)	Bloomfield: Reviewing entire footage may be burdensome; impractical to require exhaustive review	Held: Court declined to decide as a general rule; found requiring exhaustive review may be impractical and resolution depends on case specifics
Whether the OPRA request was sufficiently particular and identifiable	Gilleran: Request identified specific camera and time frame	Bloomfield: Request insufficiently particular	Held: Request was sufficiently particular; argument rejected

Mason v. City of Hoboken, 196 N.J. 51 (N.J. 2008) (OPRA’s purpose is to maximize public knowledge of public affairs)
Courier News v. Hunterdon Cnty. Prosecutor's Office, 358 N.J. Super. 373 (App. Div. 2003) (broad public access under OPRA; government bears burden to justify withholding)
Asbury Park Press v. Ocean Cnty. Prosecutor's Office, 374 N.J. Super. 312 (Law Div. 2004) (OPRA favors disclosure; cited for statutory purpose)
Tractenberg v. Twp. of W. Orange, 416 N.J. Super. 354 (App. Div. 2010) (agency must make a clear showing to invoke exemptions)
Newark Morning Ledger Co. v. N.J. Sports & Exposition Auth., 423 N.J. Super. 140 (App. Div. 2011) (courts will not accept conclusory, generalized exemption claims)
MAG Entm’t, LLC v. Div. of Alcoholic Beverage Control, 375 N.J. Super. 534 (App. Div. 2005) (standards for OPRA review and agency burden)
Bent v. Twp. of Stafford Police Dept., Custodian of Records, 381 N.J. Super. 30 (App. Div. 2005) (particularity and identifiability of requested records under OPRA)
Loigman v. Kimmelman, 102 N.J. 98 (N.J. 1986) (courts reject conclusory claims of confidentiality)