Across about six months, five CPRA requests on this case closed with conclusory search results that named no system searched, no custodian, and no record-specific withholding basis.
Over a six-month period, the City closed five separate public records requests regarding case 23-009185 with summary conclusions instead of detailed search descriptions. These closures typically stated that no records existed or that all records had been provided, but they did not name the systems searched, the staff involved, or the specific legal reasons for any withholdings. In one instance, the requester explicitly asked for the names of the systems and employees being searched, yet the City's final response did not provide those details. This lack of detail makes the City's answers difficult to verify, especially since one "no records" response was later contradicted by information the City produced for a different request. While the City may have conducted adequate searches, the documentation for these five requests only shows repetitive legal language rather than a clear account of where the City looked for information.
Five Case 23-009185 CPRA requests share the same closure problem. The City closed them with broad conclusions, either "all responsive records have been provided" or "no records responsive," without identifying what system was searched, who searched it, or what record-specific withholding basis applied R.25-3549 R.26-39 R.26-71 R.26-1061 R.26-1549.
This card does not claim that the CPRA always requires a formal search log. A full-production closure can be administrative shorthand. The problem is that these were targeted records questions, the requester asked in writing for systems and custodians on at least one request, later portal records exposed contradictions or gaps, and the closures still gave only search conclusions rather than search accounts R.25-3549 C33 C35 C36 C37.
In plain language: the City repeatedly said "we are done" or "we have no records," but did not say where it looked or who looked. That kind of answer is hard to test once later records show the earlier answer may have missed something.
Under the CPRA, any withholding or denial must identify the responsible official and the specific legal basis. An unexplained “all responsive records provided” or “no records” response becomes legally vulnerable when later records contradict it GC § 7922.540 GC § 7922.000.
R.25-3549 closed with "all responsive records have been provided" and generic exemption language, while itemized follow-ups received no item-by-item response.
On R.25-3549, the requester expressly asked which systems and custodians were being searched. The closure did not provide that identification.
The City's strongest answer is that "all responsive records have been provided" can be a sufficient closure when nothing is withheld. That is true as far as it goes. However, R.26-39’s same-day “no records” closure was directly contradicted by the City’s own later production referenced in C33. The defect preserved here is narrower: five targeted requests on one case closed without naming the search path, and the absence became material because later productions and portal records exposed specific gaps. Three closures used the same two-category exemption boilerplate, and one no-records closure collided with the City's own recent production C33. The City may have performed adequate searches, but the produced request records do not show them. This card preserves the pattern that the closure conclusions named no system, no custodian, and no record-specific basis across the five requests.
The City-cited withholding authorities at issue are GC § 7927.705 and GC § 7930.100. ---