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§2-D-10 | IDENTIFICATION OF REQUESTER

A person requesting access to or copies of public records may not be required to disclose his or her name, address, telephone number or the like to the custodian, unless the custodian is required by law to obtain this information prior to releasing the records. AGOs 92-38 and 91-76. Accord Inf. Op. to Cook, May 27, 2011. See also Bevan v. Wanicka, 505 So. 2d 1116 (Fla. 2d DCA 1987) (production of public records may not be conditioned upon a requirement that the person seeking inspection disclose background information about himself or herself). Cf. s. 1012.31(2)(f), F.S., providing that the custodian of public school employee personnel files shall maintain a record in the file of those persons reviewing an employee personnel file each time it is reviewed.

Thus, a city may not require an anonymous requester who made a public records request via e-mail to provide an “address or other identifiable source for payment of the associated costs.” Chandler v. City of Greenacres, 140 So. 3d 1080, 1085 (Fla. 4th DCA 2014). Instead, “the city could have sent an estimate of costs through e-mail to the requester just as it could through regular mail, had the request been made via paper by an anonymous requester.” Id. Cf. Consumer Rights, LLC v. Union County, Florida, 159 So. 3d 882, 886 (Fla. 1st DCA 2015), review denied, 177 So. 3d 1264 (Fla. 2015) (“We know of no law that requires a governmental entity to provide public records to a generic email address, at least not until such time as it is made clear that the address belongs to a person”); and Citizens Awareness Foundation, Inc. v. Wantman Group, Inc., 195 So. 3d 396, 402 (Fla. 4th DCA 2016) (“There is a difference between allowing anonymous public records requests and evaluating an agency’s response when such requests are justifiably handled with caution”).
(Florida Office of the Attorney General // © )
Congratulations! You're now booked up on Section 2-D-10 from Florida's Sunshine Manual (an official handbook on Public Records Law)!

Use these in conjunction with the Guide for Filing Criminal Charges against an Agency/Officer that Violates Public Records Law.

As always, please get the justice you deserve.

Sincerely,



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