Connecticut Alcohol and Drug Abuse Commission v. Freedom of Information Commission
In Connecticut Alcohol and Drug Abuse Commission v. Freedom of Information Commission, 233 Conn. 28, 657 A.2d 630 (1995), the Supreme Court of Connecticut determined that an investigative file of a sexual harassment complaint by one employee of a state agency against a coworker constituted a "personnel or . . . similar" file as set forth in the exemption provisions of Connecticut's FOIA which parallels our statute.
In so holding, the Connecticut Supreme Court stated:
We see no basis for a determination that the investigation file at issue in this case is not a "similar file" as we interpret that term. While reports of incidents occurring in the workplace are not "personnel files" per se, they may be similar to personnel files in that they may contain information that would ordinarily be considered in making personnel decisions regarding the individuals involved. Such reports would be functionally similar to information contained in the individuals' personnel files." 233 Conn. at 42, 657 A.2d at 638.