8. Confessions.

There is no statutory or case law that directly addresses confessions. However, because the only records that qualify for the open-investigation exception are documents that are investigative in nature, Hengel v. City of Pine Bluff, 307 Ark. 457, 821 S.W.2d 761 (1991), a confession contained in a document that is subject to disclosure, such as an arrest report, probably would not be exempt from the FOIA.