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4. Other


  • Georgia

    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”).

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  • Iowa

    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.

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  • Vermont

    Not addressed.

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  • Wisconsin

    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.

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