Cited by

ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 753 (2011).

ATV Watch v. N.H. Dep’t of Trans., 161 N.H. 746, 764 (2011); see RSA 91-A:8, I. The trial court explained that it could not find that the City knew that it was violating the Right-to-Know Law when it denied the plaintiff’s request because “the supreme court has never defined the limits of a reasonably described request.” Therefore, the trial court ruled, it

Although federal law is not binding on our interpretation of the Right-to-Know Law, we often “consult the decisions of other jurisdictions with similar right to know laws,” including federal interpretations of FOIA, because they “are interpretively helpful, especially in understanding the necessary accommodation of the competing interests involved.” ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 753 (2011) (quotation omitted); see 38 Endicott St.

ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 753 (2011).

II Although we generally review trial court decisions regarding discovery management and related issues deferentially under our unsustainable exercise of discretion standard, Kukesh v. Mutrie, 168 N.H. 76, 80-81 (2015), where, as here, the court’s ruling is based on its construction of a statute, our review is de novo, see ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 752, 763 (2011).

ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 763 (2011).

ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 752 (2011) (noting that we “will consider legislative history only if the statutory language is ambiguous” (quotation omitted)); State v. Jennings, 155 N.H. 768, 777 (2007) (noting that “the rule of lenity is applicable only where statutory ambiguity has been found” (quotation omitted)).

Although generally, when interpreting a statute, we consider legislative history only when statutory language is ambiguous, see ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 752 (2011), that principle does not apply here.

ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 753 (2011) (discussing that the adequacy of an agency’s search for documents is measured by “reasonableness”; that a search need not be exhaustive; and that the agency can meet its burden by producing detailed, non-conclusory affidavits that are submitted in good faith).

ATVWatch v. N.H. Dep’t of Transp., 161 N.H. 746, 752 (2011).

ATVWatch v. N.H. Dep’t of Transp., 161 N.H. 746, 752 (2011).

Resolution of PFFNH’s argument requires us to interpret RSA 91-A:5, IV, “which is a question of law that we review de novo.” ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 752 (2011) (quotation omitted).

ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 752 (2011).

Resolution of NHRS’s first two arguments requires us to interpret RSA 91-A:4, I-a, “which is a question of law that we review de novo.” ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 752 (2011) (quotation omitted).

“Resolution of this case requires us to interpret the Right-to-Know Law, which is a question of law that we review de novo.” ATV Watch v. N.H. Dep’t of Transp., 161 N.H. 746, 752 (2011) (quotation and ellipsis omitted).