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Alaska PRA Requires Disclosure of Fiscal Report and Employee Performance Evaluation

The Anchorage Daily News (newspaper) obtained an injunction in state court under the state Public Records Act (PRA), Alaska Stat. § 44.62.310 et seq, compelling the city of Anchorage to produce a tape recording. The city later refused to disclose a fiscal report and an employee evaluation, and the trial court ordered the city to release those documents under the injunction as well. The trial court also granted the city's request to depose newspaper employees. Both sides appealed.

On appeal, the Supreme Court of Alaska found that even though it was improper for the trial court to put the reports under the injunction, which specifically governed only the tape recording, since the PRA required disclosure of the reports they were properly ordered to be released. The Court also found it improper for the trial court to authorize the depositions. Therefore the trial court was affirmed in its order to disclose the reports but was reversed in regard to authorizing the depositions. See: Municipality of Anchorage v. Anchorage Daily News, 794 P.2d 584 (Alaska, 1990), rehearing denied.

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Related legal case

Municipality of Anchorage v. Anchorage Daily News