Moore v. Maroney

*23The Virginia Freedom of Information Act, Code §§ 2.1-340 through -346.1 (the Act), provides that certain “official records” in the possession of any employee of a public body are “excluded” from the Act’s disclosure requirements. Code § 2.1-342(A) and (B). Among the records excluded are “personnel records containing information concerning identifiable individuals.” Code § 2.1-342(B)(3). The Act does not define the term “personnel records.”

In August 1997, appellants Bruce Moore and WVEC Television, Inc., filed a petition for mandamus and injunctive relief against appellee Ed Maroney, in his…