Working Papers/Memoranda/Correspondence Exemption

Pre-'99 FOIA Revisions

Richmond Newspapers v. Casteen

Materials that would nonetheless be official records standing alone may become exempt correspondence if they are transmitted to a qualified office as a letter.

Redinger v. Casteen

Letters exchanged between an institution of higher learning and a law firm representing a university student are not exempt as work product compiled for use specifically for litigation.

Taylor v. Worrell Enterprises

The governor's itemized telephone bills are official records exempt from disclosure as memoranda, working papers or correspondence.

Attorney General's Opinion 1983-84 #447

General fund revenue estimates prepared by the governor's advisory boards are considered working papers of the governor; Governor's budget advisory boards must follow FOIA's meeting requirements.

Attorney General's Opinion 1982-83 #724

A draft management letter is an official record.Working papers exemption lost when chief executive officer distributes a document to others.

Attorney General's Opinion 1982-83 #707

The phrase submitted in confidence in the working papers exemption refers to reports submitted by those outside the agency, not to internal reports.

Attorney General's Opinion 1981-82 #438

Newsletters prepared by county administrator summarizing issues to be discussed at the next board of supervisors meeting are official records open to the public, even if some of the topics are the proper subject of a closed meeting.

Attorney General's Opinion 1980-81 #395

Official records routinely generated in response to various statutes do not become the working papers of the chief executive officer merely because they are passed on to that office in the ordinary course of business.

Attorney General's Opinion 1979-80 #378

School board may not use personnel exemption to discuss general personnel priorities in exeuctive session. Materials held exclusively by school superintendent are exempt working papers even if the superintendent has given a presentation to school board personnel using those materials.

Attorney General's Opinion 1976-77 #315

Materials forwarded to individual school board members from the school superintendent are not exempt under the working papers exemption.

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