George v. Knick

In George v. Knick, 188 Wis. 2d 594, 525 N.W.2d 143 (Ct. App. 1994), an inmate requested copies of certain conduct reports filed against other inmates. The custodian denied the request on the basis of a statutory exception for records which might threaten institution security. See Wis. Stat. 19.35(1)(am)2.c. The trial court denied the mandamus petition without an in camera inspection. The Court reversed, and emphasized the importance of in camera inspection. The Court said that in some circumstances an inspection might not be necessary because the content of the record could be determined from the type of document, such as a judgment of conviction.