4. Other

Not specifically addressed.

The Act “does not create any conflict or inconsistency with the federal law.” Campaign for Accountability v. Consumer Credit Research Found., 303 Ga. 828, 831, 815 S.E.2d 841, 845 (2018) (explaining that “an agency that decides to release documents that a federal statute or regulation requires to be kept confidential would not violate the Open Records Act. The agency would, however, violate the federal statute or regulation”). The Act is not preempted by federal copyright law. Spencer v. Cherokee County Sch. Dist., 2025 Ga. App. LEXIS 216, 2025 WL 1526539.

In Steele v. City of Burlington, the Southern District of Iowa discussed judicial records and the accompanying presumptive common law right of access. The Court held that the “documents filed in conjunction with Plaintiffs' and Defendants' cross-motions for summary judgment are judicial records to which the common-law presumption of access attaches.” Steele v. City of Burlington, 334 F. Supp. 972, 979 (So. Dist. Iowa 2018). The Court went on to determine there was a compelling interest behind disclosure and ordered that the judicial records be unsealed. Id. at 985. The Court did allow the Defendants to propose redactions “limited to sensitive identifying information along the lines of what Defendants have proposed in their resistance brief—to ‘birth dates, personal addresses, and social security numbers . . . .” Id. The resisters had argued because the court records were exempt from disclosure under the Iowa Open Records Act, the Court should withhold them from public access even though they were submitted in summary judgment evidence.

Geographic Information Systems (GIS), a computer system that stores, captures, analyzes, and displays geographically referenced information, often create information stored in databases. Guide to Mass. Pub. Recs. Law at 32-33 (Sec’y of State, rev. Mar. 2020), https://www.sec.state.ma.us/pre/prepdf/guide.pdf. Those databases are often submitted by private engineers who have intellectual property rights over some of the material. Those materials are not exempt under the PRL, nor do the engineers give up their intellectual property rights to those materials.

The Michigan Supreme Court has held that a federal regulation with a nondisclosure component is not a basis for exempting public records from disclosure under FOIA. ACLU of Mich. v. Calhoun Sheriff’s Off., 509 Mich. 1, 17 (2022) (“A regulation cannot serve as the basis for exempting from disclosure public records under MCL 15.243(1)(d) because a regulation is not a statute”).

See above.

Not addressed.

Federal law mandated closure of information pertaining to immigration detainees in county jail, regardless of Wisconsin Open Records Law. Voces de la Frontera, Inc. v. Clarke, 2017 WI 16, 373 Wis. 2d 348, 891 N.W.2d 803.