Cited by

¶ 30 ( Carlson, 141 Ariz. at 490–91; and Mitchell, 142 Ariz. at 334).

[the] documents are confidential and privileged or whether their disclosure would be detrimental to the best interests of the state.”

( (directing trial court to 9 ABRAHAM v. ARIZ. BD.

¶ 8 (App. 2017) (cleaned up) (-79 (1952)).

–81 (1952) (concluding that the state does not have the final authority to determine whether a record is confidential).

Salt River, 168 Ariz. at 538–39 ().

law or not.” –79 (1952) (citations omitted).

Although the balancing scheme described in [-81 , ], might, in a particular and exceptional case, lead to a conclusion similar to that reached by the court of appeals, the blanket rule advanced by that court contravenes the strong policy favoring open disclosure and access, as articulated in Arizona statutes and case law.

See, , -97 (1952) (remanding records dispute and directing documents to be produced “for the private examination of the trial judge in order that the court may determine whether [the documents] are confidential and privileged or whether their disclosure would be detrimental to the best interests of the

See, , -97 (1952) (remanding records dispute and directing documents to be produced "for the private examination of the trial judge in order that the court may determine whether [the documents] are confidential and privileged or whether their disclosure would be detrimental to the best interests of the

(citing Robison v. Fishback, 175 Ind.

[Conrad’s notes] file,” including “the TRUE creation date, the access date, the access dates for each time it was accessed, including who accessed the file as well as print dates etc.”1 The City denied the request, contending that metadata is not a P.2d 893 (1952).

The City also defended its position on the grounds that metadata is not a -79

2 ¶ 16 , , the supreme court in Griffis discussed three alternative definitions of public records.

P. 26.16(b); -79, (record required by law is a public record).

a newspaper sought to inspect certain investigative documents furnished by the Attorney General to the governor.

See, (noting that “an unlimited right of inspection might lead to substantial and irreparable private or public harm,” which must be weighed against “the general policy of open access” to determine whether disclosure is proper); -81, (holding that if disclosure “would be detrimental to the best interests of the - 6 - state,” records may be kept from the public).

See also Cox Arizona Publications; Carlson

1958-59, 1960-61 , 72 L.Ed.2d 358 (1982) (citations omitted) (The purpose of FOIA is to prevent disclosure of files containing “intimate details” and “highly personal” information, which would constitute a “clearly unwarranted invasion of privacy.”)

The State claimed that it acted with specific reason and good faith in withholding the videotapes, , -97 (1952).

In further support of its argument

-81 , and Carlson, 141 Ariz. at 490 , 687 P.2d at 1245 .

The term “public record” comprehends three alternative definitions in American case law

This, in turn, , : whether countervailing interests overrode the policy favoring disclosure.