Cited by

Thus, to determine whether the 9 ABRAHAM.

§ 41-151(2)(b); ¶ 8 (2009) (not every record of a public entity is subject to disclosure).

other matters in the custody of any officer shall be open to inspection by any person at all times during office hours.” This Court has recognized, however, that access to public records may be restricted where “the interests of privacy, confidentiality, or the best interest of the state in carrying out its legitimate activities outweigh the general policy of open access.”

See Hodai, (allowing custodian of 7 JUDICIAL WATCH, INC. v. MAYES Opinion of the Court public records to deny access in “the best interests of the state,” subject to judicial scrutiny).

Our supreme court has said that “access and disclosure is the strong policy of the law[.]”

§ 39-121 (2025),1 the court found the City had shown the documents were protected from disclosure under the “best interests of the state”

But officers and public bodies may withhold or redact such records based on “countervailing interests of confidentiality, privacy or the best interests of the state.” -91 (1984).

¶11 A requestor is generally entitled to review a copy of the “real record,” even one maintained in an electronic format, ¶ 13 (2009) (citation omitted), subject to redactions necessary to protect against risks to privacy, confidentiality, or the best interests of the state, –91 (1984); Judicial Watch, ¶ 12 (App. 2011).

Reasoning that the records were public records and the Town had not shown why disclosure of the names, videos, and photographs of the shooter and his girlfriend “would be harmful to any significant privacy interest,” “decidedly tip[ped] in favor of inspection” without redaction.

Newspapers, Inc., 201 Ariz. at 349 ¶ 19 ().

¶ 8 (2009); Phoenix Newspapers, ¶ 33 (App. 2001) (“The core purpose of the [PRL] is to allow the public access to official records and other government information so that the public may monitor the performance of government officials and their employees.” (citation and quotation o

¶19 Public officials must “make and maintain records reasonably necessary to provide knowledge of all activities they undertake in furtherance of their duties.”

Salt River Pima-Maricopa Indian Cmty.

Griffis, 215 Ariz. at 3–4, ¶ 8

r activities *147 which are supported by monies from this state or any political subdivision of this state.” As the Arizona supreme court recognized in Carlson v. Pima County, this language creates a “statutory mandate which, in effect, requires all officers to make and maintain records reasonably necessary to provide knowledge of all activities they undertake in the furtherance of their duties.” , (discussing virtually identical predecessor statute to A.R.S.

Nonetheless, a public officer may refuse release or inspection of a public record if such disclosure “might lead to substantial and irreparable private or public harm.”

5 , (holding that custodian of public records could deny inspection based on “countervailing interests of confidentiality, privacy or the best interests of the state,” subject to judicial review).

[5] , (holding that custodian of public records could deny inspection based on "countervailing interests of confidentiality, privacy or the best interests of the state," subject to judicial review).

(noting statutory exemptions for some records and that public records law did not supplant common law grounds for withholding confidential or information contrary to the state's best interests).

at ¶ 8 (-90 , -45 (1984)); see also A.R.S.

om the state or any political subdivision of the state.”3 We have held that this provision supplements the Mathews definition of public records by identifying particular “records which are open to the public for inspection under § 39- 121.”