Schill v. Wisconsin Rapids School District

¶ 144. (concurring). During the last several decades, technological advancements have revolutionized document storage and electronic communication. Prior to these advancements, an employee's personal communications, whether by note, letter, or telephone call, would not have been kept by an authority and therefore would not have been subject to disclosure under the public records law.

*634¶ 145. As a result of changing technology, however, many personal communications that are unrelated to the affairs of government and the official acts of officers and employees may now be "kept by an authority"…