Under Pennsylvania’s Right-to-Know Law, the state police provided a heavily-redacted copy of investigation regulations to the ACLU along with a letter indicating that the redactions were necessary under the RTKL’s public-safety exception. The ACLU filed an appeal with the Office of Open Records, seeking an unredacted copy. The OOR received an unredacted version for in camera review and then granted the ACLU’s appeal, forcing the state police to provide the records. The state police then appealed to the Commonwealth Court, which reversed without reviewing the unredacted document.
The Supreme Court granted allocatur primarily to set forth the scope and standard of review for courts in this administrative action and subsequent appeal. The Court held that the Commonwealth court reviewed for an abuse of discretion and for the scope of review was allowed to review any record relied upon by the administrative agency. As such, it remanded to the Commonwealth Court to review the full regulation.