Court affirms denial of State Police report in vehicle-title investigation
Commonwealth Court affirmed denial of a State Police vehicle-title investigative report under the RTKL and CHRIA in an unreported memorandum opinion.
Pennsylvania’s Commonwealth Court has affirmed the denial of a request for a State Police criminal incident report connected to a vehicle-title investigation. In an October 19 memorandum opinion, the court held that the report was exempt under the Right-to-Know Law and protected from disclosure under the Criminal History Record Information Act, known as CHRIA. [S7, pp. 15–18]
Shakia Perry sought a complete, unredacted investigative report, including internal reports, communications, officer notes and correspondence with PennDOT. State Police evidence described a 58-page report concerning an investigation into possible fraudulent titling of a 2019 Mercedes sedan. That description concerns the subject of an investigation; it is not a finding that Perry committed a crime. [S7, pp. 2–4, 12]
The court accepted the agency’s verified evidence that the report and its email components documented a criminal investigation. It upheld application of Section 708(b)(16), the RTKL’s criminal-investigation exemption, and found that CHRIA prohibited dissemination of the investigative information to a non-criminal-justice recipient. [S7, pp. 10–15]
Perry argued, among other things, that the agency should provide redactions, that alleged prior disclosure defeated withholding, and that the OOR proceedings involved procedural unfairness. The court rejected those challenges. It found the agency’s extension notice timely and no due-process violation in the handling of the appeal record. [S7, pp. 7–9, 12–15]
The opinion also rejected the requested bad-faith findings. It acknowledged that the OOR determination contained an erroneous second report number but found no evidence that the error affected the outcome or demonstrated bad faith. [S7, pp. 15–17]
The ruling is expressly labeled an unreported memorandum opinion. It affirms the June 12, 2025 OOR determination in this case. Its discussion should be read in the context of the particular investigative report and the agency evidence before the court. [S7, pp. 1, 17–18]
The ruling does not establish the truth of allegations about the vehicle or adjudicate the underlying title dispute. No independent review of the withheld report was possible for this package. Subsequent appellate proceedings have not been verified.
Official sources
- S7: Shakia Perry v. Pennsylvania State Police (Office of Open Records) — 764 C.D. 2025; 2026-10-19. Archived official PDF.
Don’t Speculate. Document.