Arizona Revised Statutes
Ariz. Rev. Stat. § 39-121 (2026)
Inspection of public records
✓ current as of May 2026
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Public records and other matters in the custody of any officer shall be open to inspection by any person at all times during office hours.
Notes of Decisions
Cited in 96
cases (26 in the last 5 years), 1964–2026 · leading case: Carlson v. Pima Cnty., 687 P.2d 1242 (Ariz. 1984).
Carlson v. Pima Cnty., 687 P.2d 1242 (Ariz. 1984). “A.R.S. § 39-121 (emphasis supplied). However, Title 39 does not contain a definition of “public records” or “other matters”.”
Arizona Bd. of Regents v. Phoenix Newspapers, Inc., 806 P.2d 348 (Ariz. 1991). “Both requested access to the information pursuant to A.R.S. §§ 39-121 to -121.03, Arizona's public records law.”
Church of Scientology v. City of Phoenix Police Dep't, 594 P.2d 1034 (Ariz. Ct. App. 1979). “The appellant sought disclosure of the documents pursuant to Arizona's document inspection statutes, A.R.S. § 39-121 et seq. This is an appeal from the trial court's judgment denying disclosure.”
Am. Civil Liberties Union v. Arizona Dep't of Child Saf., 377 P.3d 339 (Ariz. Ct. App. 2016). “Although our statutes do not expressly define the phrase “public records and other matters,” A.R.S. § 39-121.01(B) requires “[a]ll officers and public bodies” to maintain all records “reasonably necessary or appropriate to maintain an accurate knowledge of [a public entity or…”
West Valley View, Inc. v. Maricopa Cnty. Sheriff's Off., 165 P.3d 203 (Ariz. Ct. App. 2007). “” ¶3 On November 14, 2005, counsel for West Valley View wrote the Sheriffs Office, *227 stating, “[p]lease consider this letter an ongoing request under the Arizona Public Records Law, AR.S. § 39-121 et seq[.] for the [Sheriffs Office] to provide the West Valley View all of its…”
Beau Hodai v. the City of Tucson & Tucson Police Dep't, 365 P.3d 959 (Ariz. Ct. App. 2016). “§§ 12-2101(A)(1) and 12-120.21. See A’iz. R. P. Spec.”
Primary Consultants, L.L.C. v. Maricopa Cnty. Recorder, 111 P.3d 435 (Ariz. Ct. App. 2005). “2 A.R.S. § 39-121 (2001). Public policy favors disclosure.”
Salt River Pima-Maricopa Indian Cmty. v. Rogers, 815 P.2d 900 (Ariz. 1991). “The sole issue before us is whether the check distribution list is a “public record” or “other matter” of the state of Arizona and therefore subject to disclosure under Arizona’s Public Records Law, A.R.S. §§ 39-121 through 39-121.03. We have jurisdiction pursuant to article 6,…”
Scottsdale Unified Sch. Dist. No. 48 v. KPNX Broad. Co., 955 P.2d 534 (Ariz. 1998). “" A.R.S. § 39-121. There are many statutory exceptions to this public right of inspection.”
Grimm v. Arizona Bd. of Pardons & Paroles, 564 P.2d 1227 (Ariz. 1977). “1939, "Records open to the public * * *" (pertinent subject matter now covered in A.R.S. § 39-121), and were subject to inspection by any citizen unless they were "confidential [and therefore privileged] or of such a nature that it would be against the best interests of the…”
Griffis v. Pinal Cnty., 141 P.3d 780 (Ariz. Ct. App. 2006). “¶ 14 Turning to the public’s right of inspection, and after noting that Mathews had “dealt with a report which [the] Court determined not to be a public record, but which fell within the ‘other matters’ wording of AR.S. § 39-121,” id., the court in Carlson stated: We hold today…”
Griffis v. Pinal Cnty., 156 P.3d 418 (Ariz. 2007). “(PNI) filed a public records request with Pinal County (the County) pursuant to A.R.S. §§ 39-121 to - 121.03, seeking release of all e-mails sent to or received by Griffis on the County’s e-mail system from October 1 to December 2, 2005.”
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