There is no specific exemption from disclosure for public employee personnel records, but most public bodies seek to assert an exemption under the "unreasonable invasion of personal privacy" rubric. A public body's claim that an internal investigative report of a police department was per se exempt from disclosure because it contained personal information was rejected by the Supreme Court of South Carolina. Columbia v. A.C.L.U. of South Carolina, 475 S.E.2d 747 (S.C. 1996). The South Carolina Court of Appeals held in Burton v. York County Sheriff, 594 S.E. 2d 888 (S.C. App. 2004) that disciplinary records of a sheriff's deputies were not exempt from disclosure under a claim that the release of the records would constitute an unreasonable invasion of personal privacy.