A citizen's fight for transparency over Flock Safety license plate surveillance cameras
Flock Safety manufactures Automated License Plate Reader (ALPR) cameras that photograph every vehicle that passes by. The cameras capture license plates, vehicle make/model, color, and distinguishing features using "Vehicle Fingerprint" technology — creating a searchable database of vehicle movements.
The Clark County Sheriff's Office operates 8 Flock Falcon cameras and 1 Flock Falcon Flex camera on public roadways and state right-of-way. The cameras are connected to Flock's cloud-based "Wing" platform, which allows data sharing across law enforcement agencies nationwide.
The Flock cameras cost $27,000 per year, paid from the Clark County Jail Commissary Fund — money generated from inmate purchases. CCSO also signed a $647,218 contract with Axon for 48 body-worn cameras over 60 months. These purchases bypass normal county budget appropriations.
The only policy governing this surveillance system is a 3-page data dissemination SOP (CCSO-015) that primarily covers criminal database access. There are no written policies governing when officers can search ALPR data, who has access, what oversight exists, or how data is shared with other agencies.
On January 6, 2026, a public records request was filed under Indiana's Access to Public Records Act (IC 5-14-3) seeking the following:
Addresses, GPS coordinates, and installation dates of all ALPR, CCTV, traffic, facial recognition, and mobile surveillance cameras.
DENIEDAll contracts with surveillance vendors (Flock Safety, Axon), data-sharing agreements, MOUs with other agencies, and funding sources.
PARTIALLY PROVIDEDAll policies governing use, data retention, access controls, sharing protocols, audit logs, usage statistics, and compliance reports.
PARTIALLY PROVIDEDCamera registry programs, real-time crime center networks, fusion center feeds, any other networked surveillance systems.
NO RECORDSAll ALPR/Flock captures of the requestor's own vehicles — images, timestamps, location data, alerts, and any third-party shares.
DENIEDIndiana law requires a substantive response within 7 calendar days. The City took 40 days — nearly six times the legal limit. No explanation or extension was communicated.
The City's attorney cited "IC 5-14-3-10" to deny records. That section covers civil penalties — it is not an exemption from disclosure. The denial is procedurally invalid on its face.
Even under the correct statute (IC 5-14-3-4(b)(10)), the "security system" exemption covers system design — not data collected about individual citizens. License plate captures are system output, not system secrets.
The only policy provided was a 3-page SOP about data dissemination. No use policies, no retention policies, no access controls, no audit logs. The agency operates mass surveillance with virtually no written governance.
Exhibit A of the INDOT-CCSO agreement — listing all camera locations — was completely redacted. No statutory exemption was cited for the redaction, and no responsible person was identified, as required by law.
A detailed letter challenging the denials was sent on February 19, 2026, requesting the City cure deficiencies within 7 days. No response was ever received.
Written public records request submitted via email to Clark County Sheriff's Office. Acknowledged same day by A. Harrington. Request subsequently redirected to the City of Jeffersonville.
Follow-up correspondence sent on letterhead to confirm the request and emphasize the urgency of preserving ALPR data before automatic 30-day deletion.
Indiana law requires a substantive response within 7 calendar days. No response received. This constitutes a deemed denial under IC 5-14-3-9(a).
Flock Safety automatically deletes ALPR capture data on a rolling 30-day basis. Personal vehicle records requested in Item #5 — which the requestor asked to be preserved — were likely permanently destroyed due to the City's delay.
Attorney Cynthia L. Forbes responds via email. Items #1 and #5 denied citing wrong statute (IC 5-14-3-10). Items #2 and #3 partially provided with incomplete documents. Item #4: no responsive records.
Detailed reply letter sent to Attorney Forbes identifying the wrong statute citation, challenging the overbroad security exemption, and requesting the City cure all deficiencies within 7 days. Cited Indiana and nationwide case law.
The 7-day cure period expires. The City of Jeffersonville provides no response whatsoever to the cure letter.
Formal complaint filed with the Indiana Public Access Counselor (PAC) documenting six separate violations of Indiana's Access to Public Records Act.
The following documents were provided by the City in response to the records request. Notable gaps and issues are highlighted.
| Document | Date | Description | Issues |
|---|---|---|---|
| Flock Safety Service Agreement | June 8, 2022 | Original contract for 8 Falcon cameras + 1 Falcon Flex. Signed by former Sheriff Jamey Noel. $25,800 Year 1, $23,000/year recurring. | Provided |
| INDOT-CCSO LEE Agreement | Sept. 13, 2022 | Agreement between INDOT and CCSO for installing law enforcement equipment on state right-of-way. | Exhibit A (camera locations) completely blacked out. No exemption cited for redaction. |
| CCSO-015 SOP | March 1, 2023 | 3-page Standard Operating Procedure for data dissemination via IDACS/NCIC. Only policy document provided. | Does not address ALPR use policies, retention, access controls, or oversight. Only policy provided. |
| Flock Invoice INV-42352 | June 24, 2024 | $27,000 renewal invoice. Year 1 of new 24-month term (2024-2025). 8 Falcon + 1 Flex at $3,000 each. | Paid from Jail Commissary Fund (check #38228) |
| Axon BWC Agreement | Dec. 18, 2024 | 60-month, $647,218 contract for 48 body-worn cameras, docking stations, Axon Evidence cloud storage, Axon Records, and auto-transcribe services. | Provided |
| Axon PSO Acceptance | March 19, 2025 | Professional services acceptance for Axon Signal virtual installation. Signed by Assistant Chief Mark Grube. | Provided |
| Flock Invoice INV-67660 | June 23, 2025 | $27,000 renewal invoice. Year 2 of 24-month term (2025-2026). | Paid from Jail Commissary Fund (voucher #290443) |
Courts across the country are increasingly ruling that ALPR data is a public record and that citizens have a right to know what their government collects about them.
A Washington court ruled that Flock Safety ALPR images are public records because they were paid for by the cities and generated for a governmental purpose. The court rejected the argument that data stored on Flock's private cloud was not a public record. Both cities shut off their Flock cameras rather than comply.
A Virginia court ruled that a citizen's FOIA request for Flock ALPR footage of his own vehicle must be fulfilled. The court held that state FOIA law supersedes both local policies and contracts with Flock Safety. The data had already been deleted due to the 30-day retention period.
California's highest court held that mass ALPR data collection is not "investigatory" merely because it was performed by law enforcement. Indiscriminate surveillance data cannot hide behind investigatory records exemptions. Anonymized or redacted data could potentially be disclosed.
The Supreme Court held that pervasive digital location tracking implicates Fourth Amendment privacy rights. If ALPR data is significant enough to withhold on security grounds, citizens have an even greater interest in knowing what data exists about them. The government can't have it both ways.
Indiana's own appellate court rejected the attempt to "bootstrap" ordinary records into the security system exemption through a tangential connection to a security system. Data generated by a system is not the same as data about the system.
Massachusetts' highest court held that with sufficient camera density, ALPR surveillance "would invade a reasonable expectation of privacy and would constitute a search." This directly supports the argument that ALPR data is too significant to hide from citizens.
The City of Jeffersonville faces a fundamental logical contradiction:
If ALPR data is so trivial that it doesn't require a warrant to collect, then there's no basis for withholding it from citizens.
If ALPR data is so sensitive that it must be kept secret, then citizens have an even greater right to know what the government has collected about them.
The City cannot simultaneously minimize and maximize the significance of ALPR surveillance data.
On March 3, 2026, a formal complaint was filed with Public Access Counselor Jennifer Ruby documenting six separate violations of Indiana's Access to Public Records Act by the City of Jeffersonville. The complaint is currently awaiting review and an advisory opinion.