Pennsylvania State Troopers Ass'n v. Scolforo, 2011 Pa. Commw. LEXIS 166

Scolforo sought PSP records of supplementary employment requests since Jan. 1, 2005, including responses, outcomes, and related records.
PSP provided some policies but denied most records as exempt under RTKL 708(b)(10)(i)(A), 708(b)(17), or due to redaction needs for risk of harm and personal identifiers.
OOR granted partial relief, ordering redactions of social security numbers and home addresses and allowing redaction of location/scheduling data.
PSTA sought to intervene; OOR granted intervention and issued a final determination favorable to Scolforo on most records.
PSP and PSTA challenged OOR’s ruling on the exemption analyses under 708(b)(1)(ii) and 708(b)(6); PSP did not appeal.
Court reviews the RTKL exemptions narrowly and determines redactions are permissible to balance transparency with safety.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 708(b)(1)(ii) exempts records showing risk of harm.	Scolforo/PSP troopers’ records show specific locations/schedules; disclosure risks harm.	PSP proves that advance knowledge could expose troopers to harm; records should be exempt.	Not exempt as to most records; redaction of location/scheduling is required.
Whether 708(b)(6) exempts personal identifiers in these records.	Personal identifiers reveal sensitive link to private employment; exemption should apply.	Redaction allowed under 708(b)(6)(iii) and 506(c) to balance access.	Accessible after redaction; redacted social numbers/home addresses suffice to protect privacy.

Bowling v. Office of Open Records, 990 A.2d 813 (Pa.Cmwlth.2010) (exemptions narrowly construed; RTKL access remedial)
Lutz v. City of Philadelphia, 6 A.3d 669 (Pa.Cmwlth.2010) (general safety concerns insufficient to establish 708(b)(1)(ii).)
Stein v. Plymouth Twp., 994 A.2d 1179 (Pa.Cmwlth.2010) (plenaries of legal question review under RTKL)