b. Rules for closed investigations.

In Bougas v. Chief of Police of Lexington, 371 Mass. 59 (1976), the Supreme Judicial Court refused to compel disclosure of investigatory materials, including letters from citizens who witnessed the incident subject to investigation.  Even though the investigatory reports had been disclosed to a limited group and that the investigation had been concluded, the court found that confidentiality was necessary to enable the police to investigate

The Supervisor of Public Records had made it clear that pre-arrest reports or data, names of informants and witnesses, and surveillance data cannot be withheld based on the C.O.R.I. law.  SPR Bulletin No. 3-03 (Sec’y of State, Nov. 21, 2003) (noting that such information might be withheld under another exemption, if applicable).