Free Market Environmental Law Clinic v. Attorney General of New York

The New York Appellate Division ruled that the New York attorney general met its burden of establishing that it had properly withheld records related to meetings with representatives of outside organizations in 2015 that concerned the attorney general’s investigation of ExxonMobil Corporation’s climate change disclosures. The appellate court upheld the attorney general’s determination that the records were exempt from disclosure under New York’s Freedom of Information Law because they were compiled for law-enforcement purposes. The court did not consider whether the documents would also be exempt as intra-agency materials.