25-ORD-398 – Victor Lawless/Lebanon Police Department

Opinion Content:

December 11, 2025

In re: Victor Lawless/Lebanon Police Department

Summary: The Lebanon Police Department (“the Department”) did not
violate the Open Records Act (“the Act”) when it denied a request that
failed to contain the name of the applicant.

Open Records Decision

On October 30, 2025, Victor Lawless (“Appellant”) submitted a request to the
Department seeking body-worn camera footage, dashboard camera footage, and a
citation related to specific traffic accident. The Appellant’s request did not include a
statement explaining how he qualified as a resident of the Commonwealth, and in his
subsequent communication regarding his request, he stated that the name under
which he submitted his request is an alias. The Department then asked that the
Appellant provide his actual name. Upon the Appellant’s refusal to do so, the
Department denied his request. This appeal followed.

All applications to inspect records must contain the name and signature of the
person making the request. KRS 61.872(2)(a) (authorizing the official custodian to
require that an application be “signed by the applicant and with his or her name
printed legibly on the application”). “[A]n application for records that includes a
pseudonym instead of the requester’s real name fails to comply with
KRS 61.872(2)(a).” 25-ORD-171; see, e.g., 22-ORD-122 (finding an anonymous request
did not comply with KRS 61.872(2)(a)); 21-ORD-115 (same). Here, the Appellant
admits that “Victor Lawless” is not his or her real name. 1 Accordingly, he or she did
not comply with the requirement in KRS 61.872(2)(a) that a request include the

1 See, e.g., KRS 365.015(1)(a) (“The real name of an individual shall include his or her surname at
birth, or his or her name as changed by a court of competent jurisdiction, or the surname of a married
woman.”).

requester’s name. Thus, the Department did not violate the Act when it denied the
Appellant’s request.

A party aggrieved by this decision may appeal it by initiating an action in the
appropriate circuit court under KRS 61.880(5) and KRS 61.882 within 30 days from
the date of this decision. Under KRS 61.880(3), the Attorney General shall be notified
of any action in circuit court, but shall not be named as a party in that action or in
any subsequent proceedings. The Attorney General will accept notice of the complaint
emailed to [email protected].

Russell Coleman
Attorney General

/s/ Zachary M. Zimmerer
Zachary M. Zimmerer
Assistant Attorney General

Victor Lawless
Wesley Cox, Chief Record Clerk, Lebanon Police Department