St. Louis County, MO., City of University City, MO., City of Webster Groves, MO. Missouri Cases

Phillip Weeks appealed the circuit court's grant of summary judgment in favor of Webster Groves and St. Louis County in his lawsuit alleging violations of Missouri's Sunshine Law. Weeks had requested "raw data files" and "data generated from vehicle stop forms," including Department Serial Numbers (DSNs). The Missouri Supreme Court vacated the circuit court's judgment and remanded the case for further proceedings, holding that while electronically stored raw data can be a public record, the Sunshine Law does not require the creation of new records. The Court found that the summary judgment record was insufficient to determine whether the DSNs were responsive public records, required the creation of a new record, or were exempt from disclosure.