1. What kind of records are covered?

The Alabama Public Records Law does not define "public writing," which are the operative words in the Law. A statute in a different section of the Alabama Code purports to define the term "public records" as including

all written, typed or printed books, papers, letters, documents and maps made or received in pursuance of law by the public officers of the state, counties, municipalities and other subdivisions of government in the transactions of public business and shall also include any record authorized to be made by any law of this state belonging or pertaining to any court of record or any other public record authorized by law or any paper, pleading, exhibit or other writing filed with, in or by any such court, office or officer.

Ala. Code § 41-13-1 (2000) (emphasis added). The definition of "public records" in section 41-13-1 is limited by its terms, however, to the article in which the definition appears.

In Stone v. Consolidated Publishing Co., 404 So. 2d 678, 680-81 (Ala. 1981), the Supreme Court of Alabama held that a "public writing" within the meaning of Alabama's Public Records Law includes those documents that are within the definition of "public record" in section 41-13-1, but also includes any such "record as is reasonably necessary to record the business and activities required to be done or carried on by a public officer so that the status and condition of such business and activities can be known by our citizens." Stone, 404 So. 2d at 681 (emphasis in original).

The Alabama Public Records Law has been held to require disclosure of documents such as the following:

a. Actuarial tables used to calculate teacher retirement benefits, Walsh v. Barnes, 541 So. 2d 34 (Ala. Civ. App. 1989).

b. Arrest reports, Birmingham News Co. v. Deutcsh, CV 85-504-132 JDC (Cir. Ct. of Jefferson County, Ala., Equity Div., Aug. 19, 1986).

c. Minutes, International Ass'n of Firefighters v. City of Sylacauga, 436 F. Supp. 482 (N.D. Ala. 1977).

d. Municipal internal audit reports, Bedingfield v. Birmingham News Co., 595 So. 2d 1379 (Ala. 1992).

e. Petitions, State ex rel. Kernells v. Ezell, 291 Ala. 440, 282 So. 2d 266 (1973).

f. Preliminary report prepared at the request of a state university concerning the alleged misconduct of one of its employees, Advertiser Co. v. Auburn Univ., 17 Media L. Rep. (BNA) 1907 (Cir. Ct. of Lee County, Ala., Mar. 29, 1990), aff'd, 579 So. 2d 645 (Ala. Civ. App. 1991) (denial of attorneys' fee was only issue on appeal).

g. Resumes and employment applications, Chambers v. Birmingham News Co., 552 So. 2d 854 (Ala. 1989).

h. State court records, Holland v. Eads, 614 So. 2d 1012, 1015 (Ala. 1993).

i. State vehicle license tag records, Birmingham News Co. v. Hobbie, 12 Media L. Rep. (BNA) 1687 (Cir. Ct. of Montgomery County, Ala., Dec. 20, 1985).

j. Well-bound books containing jail dockets, Holcombe v. State ex rel. Chandler, 240 Ala. 590, 200 So. 739 (1941).