Florida Supreme Court: Times Publishing v. City of Clearwater. In a nutshell, Times Publishing asserted that all emails sent/received by public officials (and thus residing on government-owned computer system(s)) were automatically public records, and the city said, no, some stuff is personal, some stuff is official business, and therefore public records. The court agrees with the city.

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we conclude "personal" emails are not "made or received pursuant to law or ordinance or in connection with the transaction of official business" and, therefore, do not fall within the definition of public records in section 119.011(1) by virtue of their placement on a government-owned computer system.