Cited by

Also, in Hodai v. City of Tucson, the court of appeals determined that information from an ongoing and sensitive investigation may be withheld when disclosure would jeopardize that investigation: “[T]he harm here is specific—even providing the name or minor details of the investigation would link it to the use of the equipment, revealing a sensitive investigative technique in an ongoing case.” ¶ 21 (App. 2016).

A public-records search must be “reasonably calculated to uncover all relevant documents.”

“Both the determination that the petitioner substantially prevailed and the award of fees after making such a finding are at the discretion of the trial court.” ¶ 41 (App. 2016).

¶38 Although Defendants have the initial burden to show they adequately searched for responsive records, they can discharge their burden through “affidavits or declarations that provide reasonable detail of the scope of the search.” ¶ 30 (App. 2016) (citations omitted).

¶ 27 (App. 2016) (explaining that an “unreasonable administrative burden” can justify the denial of a public records request).

But, “[a] person’s right to public records under [§ 39-121] is not conditioned on his or her showing, or a court finding, that the documents are relevant to anything.” (first alteration added, second alteration in Hodai) (quoting Bolm v. Custodian of Recs.

Hodai v. City of Tucson , , ¶ 41

§ 39-121.01(D)(2) (privilege log); ¶ 27 (App. 2016) (redaction is one part of the administrative burden of producing public records).

at 538 ¶ 11, but gives deference to findings unless clearly erroneous, ¶ 8 (App. 2016).

See, ¶ 9 (2003); ¶ 27 (App. 2016) (a search of 1400 email accounts that would have to be reviewed and redacted, plus documents normally available in hard copy form only, required a “time-intensive and costly manual search of all paper records” and was “unreasonably burdensome,” not requiring inspection by the agency); Judicial Wa

Phoenix New Times, ¶ 16 (App. 2008) (citation omitted); ¶ 32 (App. 2016) ("[T]he agency must demonstrate its search was reasonably calculated to uncover all relevant documents.") (internal quotation and citation omitted).

¶ 36 (App. 2016) (citing In re 1996 Nissan Sentra, ¶ 7 (App. 2001), ¶ 9 (App. 2014)).

¶ 36 (App. 2016) (citing In re 1996 Nissan Sentra, ¶ 7 (App. 2001), ¶ 9 (App. 2014)).

¶ 36 (App. 2016) (citing In re 1996 Nissan Sentra, ¶ 7 (App. 2001)).

at 395, ¶ 10 , 267 P.3d at 1187 ; ¶ 7