City of Sunny Isles Beach v. Gatto
A city commissioner was observed texting during a Zoom commission meeting; a resident's chapter 119 public records request led the trial court, after in camera review, to order disclosure of texts between the commissioner and her husband. The Third DCA reversed, holding that the purely personal texts between the commissioner and her husband were not made 'in connection with the transaction of official business' and thus are not public records, even though sent during a public meeting and touching on city topics.
Key facts
- City resident submitted a Chapter 119 public records request for text messages exchanged between a city commissioner and her husband that were sent during a Zoom commission meeting.
- The trial court, after reviewing the messages in camera, ordered the city to disclose the texts, finding them subject to public records laws.
- +2 more key facts with a free trial
Why it matters
Provides a useful Third DCA line-drawing decision on when an elected official's private-device text messages are public records, emphasizing the 'transaction of official business' element over the time, place, or… — full analysis with a trial
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