Messages on Government Officials’ Personal Devices and Private Accounts Not Subject to California Public Records Act

City of San Jose public officials’ communications sent and received on their personal electronic devices using private accounts need not be disclosed as they are not public records under the California Public Records Act (“CPRA”), the California Court of Appeal has ruled unanimously. City of San Jose v. Super. Ct. (Smith), No. H039498 (Cal. Ct. App. Mar. 27, 2014).