Office of Information Practices

U Memo 26-04
October 29, 2025
Reasonable Search for Records

Requester made a record request to the City and County of Honolulu Police Department (HPD) for a copy of a hospital report that was part of a court case.  HPD denied the record request and informed Requester that the specific hospital report he requested did not exist.  Requester appealed the denial to HPD.  When an agency’s response to a record request states that no responsive record exists and that response is appealed, OIP assesses whether the agency’s search for a record was reasonable.  HPD explained that after identifying the HPD reports that were related to the court case Requester referenced, HPD determined that the date of the incident meant that any responsive records would be in HPD’s Microfilm System.  HPD explained that it had searched the Microfilm System and located the reports in question, and after reviewing the approximately ninety pages of reports determined that HPD did not maintain a copy of the specific hospital report Requester sought.  OIP found that HPD’s search was reasonably calculated to uncover all relevant documents and could reasonably be expected to produce any records HPD maintained that were responsive to the request.  Therefore, OIP concluded that HPD’s response that it did not maintain records responsive to the request was proper and HPD had no further obligations under the UIPA regarding the request.