On September 29, 2015, the Government Records Council (GRC) ruled that the City of East Orange must accept Open Public Records Act (OPRA) requests by either fax or e-mail and cannot restrict requestors' OPRA submissions to regular mail or hand-delivery.
In the case, Dello Russo v. East Orange, the GRC held that East Orange's "policy of banning submission of OPRA requests electronically represents an unreasonable obstacle on access." It held that while the City did not need to accept OPRA requests by both fax and e-mail, it must accept some form of electronic submission.
This decision clarifies the Appellate Division's May 21, 2009 decision in Paff v. City of East Orange. There, Appellate Division Judge Stephen Skillman affirmed the GRC's ruling that "there is no basis for concluding that East Orange's form, which only prohibits submission of OPRA requests by fax, but allows submission by mail or 'electronically,' imposes any undue burden upon parties who seek the disclosure of government records under OPRA."