Griffis v. Pinal County
In Griffis v. Pinal County, 215 Ariz. 1, 3, P7, 215 Ariz. 1, 156 P.3d 418, 420 (2007), the Arizona Supreme Court explained the process to be followed by a court when the presumption in favor of disclosure of public records comes into conflict with asserted privacy interests.
Determining whether the public records law requires disclosure, then, involves a two-step process. When the facts of a particular case "raise a substantial question as to the threshold determination of whether the document is subject to the statute," the court must first determine whether the document is a public record.
If a document falls within the scope of the public records statute, then the presumption favoring disclosure applies and, when necessary, the court can perform a balancing test to determine whether privacy, confidentiality, or the best interests of the state outweigh the policy in favor of disclosure. Id. at 5, P 13, 156 P.3d at 422.