State, Department of Employment, Training & Rehabilitation v. Sierra National Corp.
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The Supreme Court affirmed the order of the district court granting the Love Ranch's petition for a writ of mandamus and compelling the Department of Employment, Training & Rehabilitation (DETR) to comply with the Love Ranch's public records request for various records related to audits of the Love Ranch and other legal brothels, holding that Nev. Rev. Stat. 612.265 did not categorically exempt the requested records from disclosure.
After the DETR's Employment Security Division (ESD) audited the Love Ranch the Love Ranch made a formal records request asking that DETR produce all records related to the audit and past audits and decisions regarding the Love Ranch and other brothels. DETR denied the request. The Love Ranch then petitioned the district court for a writ of mandamus, which the district court granted. The Supreme Court affirmed, holding (1) section 612.265 protects from disclosure a person's or employing unit's identity but otherwise does not prohibit disclosure of the ESD's records; and (2) because the request in this case expressly excluded any records that would reveal a person's or employing unit's identity and the district court did not compel disclosure of any records beyond those requested, the district court properly granted the petition for a writ of mandamus.
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