Appellate Division Reverses Summary Judgment for Failure to Conduct Required In‑Camera OPRA Review

The appellate division reversed a trial court’s granting of summary judgment because it did not conduct an in-camera review of documents under the Open Public Records Act (OPRA). The trial court improperly relied upon the state’s certification as to the documents sought. This case is significant because it further provides direction to trial courts that an in-camera review of the documents is best practices in deciding motions for summary judgment as to alleged violations of the OPRA, simply on the briefs and certifications submitted.