Reno Newspapers v. Gibbons

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Justia Opinion Summary

Appellant made a records request pursuant to the Nevada Public Records Act (NPRA) for email communications between the former governor and ten individuals. The State informed Appellant that the requested emails were confidential because they were either privileged or not considered public records. Appellant then filed a writ of mandamus in the district court seeking access to the emails or, in the alternative, to receive a detailed log or index containing a general factual description of each of the records withheld and a specific explanation for nondisclosure. After an in-camera review of the emails, the district court (1) denied Appellant's request for a detailed log or index, and (2) determined that six of the 104 requested emails were not confidential, thereby granting the petition as to the six emails. The Supreme Court reversed, holding that the district court erred in denying Appellant's request for a log because (1) after the commencement of an NPRA lawsuit, the state entity withholding requested records is generally required to provide the requesting party with a log; and (2) in the instant case, the State failed to meet its prelitigation responsibilities under the NPRA.

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