In March, the State Supreme Court published a decision that held that any records (emails, texts, etc.) on public employees’ private phones, computer or servers that relate to public business are public records and may be disclosed under the California Public Records Act (City of San Jose v. Superior Court).
Prior to this court decision, the state law had been that if the public employees’ records relating to public business were on their private phones or computers, they were not subject to disclosure under the CPRA, since they were not controlled by the public employee’s agency.