California Supreme Court held that personal email used for public business is subject to disclosure

On March 2, the California Supreme Court held that emails sent to or from the personal accounts of public officials can be subject to disclosure if they are used to conduct public business. The decision stems from a 2009 public records request made to the city of San Jose.

The full text of the ruling can be found here.

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Illinois AG Rules That Public Employees’ Personal Emails Are Public Records

Illinois Attorney General Lisa Madigan has issued a binding opinion under the state's Freedom of Information Act (FOIA) that email messages sent or received through public employees' personal email accounts may be public records subject to disclosure under FOIA if the messages pertain to public business.

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