Arpaio v. Davis
In Arpaio v. Davis, 221 Ariz. 116, 210 P.3d 1287 (App. 2009), the sheriff had requested "thousands of random" emails with no identifying subject matter that had been exchanged among judges, staff, and legal counsel of the Maricopa County Superior Court. Id. at 117-18,2, 210 P.3d at 1288-89.
The superior court upheld the denial of the request under Supreme Court Rule 123, which governed requests for judicial records. Id. at 120-21,20, 210 P.3d at 1291-92.
It found that the records request created an undue burden by diverting equipment, materials, and time from the court's mandated functions and by seeking to expose work product long exempt from disclosure. Id. at 20-21 and n.5, 210 P.3d at 1291-92 and n. 5.
The Court affirmed that ruling. Id. at 121,22, 210 P.3d at 1293.