Silverman v. Ariz. Dept. of Econ. Sec., CV-23-0181-PR, 6/3/24.

 

     Investigative journalists can engage in “bona fide research” under A.R.S. § 46-460(D)(8), an exception to the general rule that certain records pertaining to abuse, exploitation, or neglect of vulnerable adults must be shielded from public inspection.  Adult Protective Services (APS) operates a program within the Arizona Department of Economic Security (ADES).  Although Arizona law provides a general right to inspect public records, APS records are presumptively restricted from release.  A statutory exception to that presumption provides that ADES employees may release records to “any person who is engaged in bona fide research,” if other criteria are met.  Because the exception applies to “any person,” without limitation, investigative journalists may qualify for the exception.  

 Disclaimer