4. Investigatory records.

The assertion that a criminal matter “remains, an open and ongoing investigation” is not a sufficiently specific justification for refusing public access to a police incident report. Portage Daily Register v. Columbia County Sheriff’s Dept., 2008 WI App 30, ¶ 13, 308 Wis. 2d 357, 746 N.W.2d 525. Non-disclosure may be justified under the balancing test on a case-by-case basis, however, if the custodian can show “that disclosure would interfere with an ongoing investigation.” Id., ¶ 20.