Kentucky's Attorney General has upheld the Kentucky State Police's denial of a duplicate records request, finding the agency did not violate the Open Records Act when it refused to reproduce documents a second time without justification.

In a decision issued Feb. 10, La'Daya Daniels, who sought body camera audio and dispatch records related to her arrest, appealed KSP's denial of her second request for materials she said were missing from an earlier production. According to the Attorney General's decision, KSP correctly rejected the duplicate request because Daniels "failed to show some justification for resubmitting that request."

The Attorney General's office noted that Kentucky law generally allows agencies to deny duplicate requests as imposing an "unreasonable burden" on government operations. In previous cases, the office has stated that agencies are not "required to satisfy the identical request a second time in the absence of some justification for resubmitting that request," such as loss or destruction of records.

Daniels indicated she was resubmitting the request because certain records appeared absent from KSP's initial production. KSP asserted it had informed Daniels that other requested documents did not exist and that it "provided [the] Appellant with all recordings relating to her arrest" in the previous request. However, the previous request and KSP's response were not at issue in the Attorney General's appeal.

The decision comes as Kentucky State Police have deployed body-worn cameras to troopers for the first time in the agency's history. KSP received $12.2 million in state funding to purchase approximately 780 body cameras and in-car recording systems. Kentucky's Open Records Act grants residents the right to request public records from government agencies, though the law includes various exemptions and allows agencies to deny requests that place unreasonable burdens on operations.

Daniels has 30 days from the decision's date to appeal to circuit court if she chooses to do so.