Director upholds Layton City’s withholdings for unsustained complaints, attorney‑client, and prosecution records

Gage Wilson appealed for records surrounding his interactions with Layton City Police, seeking investigative reports, communications about a firearm release and property seizure, and surveillance or body‑camera footage. "This appeal is about whether Layton City conducted a complete and good faith response to my GRAMA request," Wilson told the director.

Layton City argued that unsustained citizen complaints are private personnel records and excluded from public disciplinary records; it also said two disputed emails between police administration and the city attorney were privileged and that some prosecution‑related materials were withheld because prosecution remained pending. The city said it conducted targeted searches, escalated partitioned criminal files appropriately, and provided one ATF firearms trace summary upon appellate review.

Director Pearson reviewed the written materials and in‑camera records and found the city had conducted a reasonable search. He agreed the unsustained complaints qualify as private personnel records and that attorney‑client/work‑product protections and prosecution‑related protections justified withholding certain files. The appeal was denied; a written decision will follow within seven business days.

Why it matters: The ruling reiterates narrow limits on disclosure of internal investigation and personnel materials and reconfirms that ongoing prosecutions can justify temporary withholding of records that could affect proceedings.