Police and Investigative Agencies (Confidentiality of Investigatitive Files)
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Wheeler v. Gabbay
FOIA and the discovery rules of the Supreme Court are mutually exclusive. Under FOIA, citizens are entitled to criminal incident reports that describe the criminal act.
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James v. Division of Consolidated Services
Va FOIA excludes evidence related to a criminal investigation unless needed for criminal defense.
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Attorney General’s Opinion 1984-85 #424
Reports filed in confidence with state or local police are exempt.