Garrison v. Bailey

Appellant Jeffrey Garrison challenges the circuit court’s denial of his petition for a writ of mandamus, in which he claimed the Florida Department of Law Enforcement wrongfully asserted that certain records he sought by way of a public records request were exempt from disclosure. The circuit court denied relief without inspecting the records at issue.

As we have noted, an in-camera inspection of assertedly exempt records is generally the only way for a trial court to determine whether or not a claim of exemption applies. See Weeks v. Golden, 764 So.2d 633, 635 (Fla. 1st DCA 2000) (with…