The California Supreme Court, reversing the Court of Appeal, held that email communications on private accounts by public officials are public records and thus subject to disclosure under the California Public Records Act (CPRA) if related to the conduct of public business. The privacy of the city employees did not outweigh the interest in transparency of public business as stated in the California state constitution. Ted Smith sued the city of San Jose, California under CPRA for the production of emails and text messages concerning redevelopment efforts in downtown San Jose from city employees’ personal accounts. The Court was concerned that if public officials could circumvent the law simply by using a different email account, or communicating through a personal device, sensitive information could routinely evade public scrutiny. The Court ruled that transparency in government activities was essential and while it was important to be sensitive to the privacy of public officials, this did not justify a categorical exclusion of all communications on personal accounts especially when personal communications unrelated to the conduct of public business could be redacted and excluded from public disclosure.