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23-ORD-291

November 1, 2023

In re: Kenny Goben/Louisville Metro Police Department

Summary: The Office cannot find that the Louisville Metro Police
Department (“the Department”) violated the Open Records Act (“the
Act”) because the Office cannot resolve the factual dispute between the
parties as to whether the Department received the request.

Open Records Decision

Kenny Goben (“Appellant”) claims that, on September 15, 2023, he mailed a
request to the Department for records.1 On October 1, 2023, having received no
response from the Department, the Appellant initiated this appeal.

Under KRS 61.880(1), upon receiving a request for records under the Act, a
public agency “shall determine within five (5) [business] days . . . after the receipt of
any such request whether to comply with the request and shall notify in writing the
person making the request, within the five (5) day period, of its decision.” Here, the
Appellant claims he submitted a request to the Department on September 15, 2023,
but it did not respond to his request. In contrast, on appeal, the Department states it
did not respond to the Appellant’s request because it never received it.2 The Office
has previously found it is unable to resolve factual disputes between a requester and
a public agency, such as whether an agency received a request. See, e.g., 22-ORD-100;

1
The Appellant requested the “names of all LMPD Officers that were convicted in court for using
‘Fake or Forged’ search warrants from 1990-2015.” The Appellant further specified that the
Department’s response to his request should include “a copy of the indictment and circuit case number
for each officer convicted.”
2
The Appellant mailed his request to a specific officer, but he did not provide the mailing address
to where he mailed it. The Department states the officer to whom the Appellant addressed his request
“retired in July of 2017.”22-ORD-051; 21-ORD-163. Accordingly, the Office cannot resolve the factual dispute
between the parties as to whether the Department received the Appellant’s request,
and it therefore cannot find the Department violated the Act.

A party aggrieved by this decision may appeal it by initiating an action in the
appropriate circuit court under KRS 61.880(5) and KRS 61.882 within 30 days from
the date of this decision. Under KRS 61.880(3), the Attorney General shall be notified
of any action in circuit court, but shall not be named as a party in that action or in
any subsequent proceedings. The Attorney General will accept notice of the complaint
emailed to OAGAppeals@ky.gov.

Daniel Cameron

Attorney General

s/ Matthew Ray

Matthew Ray

Assistant Attorney General

#438

Distributed to:

Kenny Goben
Alice Lyon
Nicole Pang
Natalie S. Johnson
Annale Taylor

LLM Summary
In 23-ORD-291, the Office of the Attorney General could not determine whether the Louisville Metro Police Department violated the Open Records Act as it could not resolve the factual dispute about whether the Department received the records request from the appellant. The decision cites previous rulings that establish the Office's inability to resolve such factual disputes.
Disclaimer:
The Sunshine Law Library is not exhaustive and may contain errors from source documents or the import process. Nothing on this website should be taken as legal advice. It is always best to consult with primary sources and appropriate counsel before taking any action.
Requested By:
Kenny Goben
Agency:
Louisville Metro Police Department
Forward Citations:
Neighbors

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