Annotation for 406 S.W.3d 842

Law enforcement exemption in KRS 61.878(1)(h) is appropriately invoked only when an agency can articulate a factual basis for applying the exemption when, because of a record’s content, the record’s release poses a concrete risk of harm to the agency in a prospective action, which must be something more than a hypothetical or speculative concern. City of Fort Thomas v. Cincinnati Enquirer, 406 S.W.3d 842, 2013 Ky. LEXIS 375 (Ky. 2013).