Blackstock v. Virginia Department of Transportation (COA)


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The Court of Appeals for Virginia rules that VDOT could assert an exemption for the first time on appeal because the exemption contained a prohibition against release of specific information; it was an ‘other law’ that prohibited release. The exemption at issue is 2.2-3705.3(7): ““Investigative notes, correspondence and information furnished in confidence, and records otherwise exempted by [VFOIA] or any Virginia statute, provided to or produced by or for . . . internal auditors appointed by the head of a state agency.”

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