Griffis v. Pinal County: Establishing When a Public Official’s Personal Emails Are Public Records Subject to Disclosure

In Griffis v. Pinal County, the Arizona Supreme Court addressed whether “purely personal” emails created and maintained on government-owned computer systems are public records within the scope of Arizona’s public records law. In a 5-0 decision, the court held that such emails are not public records per se. Noting, however, the strong public policy favoring disclosure of public documents, the court held that if, after an in camera review, an email is found to be a public record, there is a presumption in favor of its disclosure, though privacy, confidentiality, or the best interests of the state may outweigh this presumption.