West Valley View, Inc. v. Maricopa Cnty, Sheriff's Office
In West Valley View, Inc. v. Maricopa Cnty, Sheriff's Office, 216 Ariz. 225, 165 P.3d 203 (App. 2007), the sheriff's office refused numerous requests to add a newspaper to an email distribution list and required that the newspaper request each of the sheriff's press releases as it was issued, even if the newspaper had no way of knowing when that might be. Id. at 229,14, 165 P.3d at 207.
Although the sheriff's office argued that it could not be ordered to provide releases that were not yet in existence, we held that its obligation "ripened upon the creation of each future press release." Id. at17.
Moreover, no statutory provision barred the newspaper's on-going request, id. at15; the request was for clearly public records that had to be "promptly" disclosed, and the sheriff's office did not allege any prejudice or inconvenience from the request. Id. at 230,21, 165 P.3d at 208.