A trial court properly dismissed an Article 78 proceeding filed by the operator of two websites containing jail booking photos, who was denied a request to obtain mugshots of New York City jail detainees, an appellate court found.

The Appellate Division, Second Department, ruled June 3 in Matter of Prall v. New York City Department of Corrections, 9354/12, that Kyle Prall, whose Texas-based company publishes criminal records and charges fees to remove them, did not show a public interest in obtaining the mugshots of every arrestee booked into Department of Correction (DOC) detention facilities in August 2011.

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