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Story Publication logo May 12, 2021

Analysis of Police Misconduct Record Laws in All 50 States

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Dozens of police officers cross a street.
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Several roadblocks stand in the way of police accountability. Some are legal—qualified immunity; the...

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Police officers in riot gear line up across a street.
In this Aug. 8, 2020 photo, Portland, Ore., police officers in riot gear stand guard near the Portland police union building. Despite passage of a 2020 Oregon law tracking decertified officers statewide, most complaints of misconduct remain closed. Image by Maranie Rae Staab via AP. United States.

Below is an analysis of public record laws in all 50 states. It is based on an analysis of statutes and court opinions as well as interviews with experts. To stay up to date with the rapidly changing laws, visit Legislative Responses for Policing-State Bill Tracking Database.

This reporting is funded by the Pulitzer Center on Crisis Reporting.

ALABAMA-RESTRICTED

Police disciplinary records are available to the public, but agencies can require that requesters state the reason for their request.

A 1995 opinion by then Alabama Attorney General Jeff Sessions opened the door to agencies withholding documents, said Sam Stecklow, a journalist with the Invisible Institute, a nonprofit journalistic group focused on public accountability.

Agencies can deny requests because the release of the records “could reasonably be expected to be detrimental to the public safety or welfare, and records the disclosure of which would otherwise be detrimental to the best interests of the public.” Stecklow also points out that the law does not address release of misconduct records where there is no punishment.

Alabama enacted a law this spring to create a statewide database of police misconduct to help police departments avoid hiring officers with problems. But the law closes the database to the public.

ALASKA-MOSTLY CLOSED

Police misconduct records in Alaska are generally not available because state employee’s personnel and disciplinary records are exempted from the Alaska Public Records Act (A.S. 39.25.080). There is also no database that tracks shootings or use of force in the state.

The Alaska Supreme Court ruled last year that disciplinary records for Alaskan State Troopers are confidential. Alaska has come under fire from local media organizations and the Reporter’s Committee for Freedom of the Press for this exception.

When a police department fires an officer or disciplines an officer for serious misconduct, it must report the discipline to the Alaska Police Standards Council. If the disciplined officer does not contest the action, the information is confidential. If the officer contests the action, there is a public hearing process.

Dozens of police officers with criminal records have worked in Alaska’s cities, despite a state law that should have disqualified them, an investigation by the Anchorage Daily News and ProPublica found. One of these officers was Nimeron Mike, a registered sex offender who had spent six years in prison and been convicted of assault, domestic violence and other crimes.

ARIZONA-MOSTLY PUBLIC

Police misconduct records are generally available to the public as long as any investigation concerning the misbehavior has been completed, according to Arizona Statute 39-128. Local TV station ABC15 compiled the “Brady lists” from all the counties — lists of officers not considered honest enough to testify in court. The lists totaled 1,400 officers. The station found that prosecutors often failed to disclose that an officer was on the list.

The Arizona House passed a bill this year, supported by the Phoenix Law Enforcement Association, that would have closed the list. It hasn’t passed the Senate.

Another investigation conducted by the Arizona Republic discovered that Phoenix police frequently purge officers’ records to keep police misconduct a secret.

Arizona also provides an “integrity bulletin” in accordance with the National Decertification Index on the International Association of Directors of Law Enforcement Standards and Training’s website but it doesn’t disclose the names of officers disciplined in this bulletin. Arizona is one of 11 states that provide this public bulletin.

ARKANSAS-MOSTLY CLOSED

Police misconduct records are not available to the public unless one can prove a compelling public interest and they deal with an officer’s official suspension or termination. Personnel records are not eligible to be requested to the extent that disclosure would constitute a clearly unwarranted invasion of personal privacy, according to Arkansas Code § 25-19-105.

CALIFORNIA-RESTRICTED

In 2018 the state’s legislature passed SB1421, the Right To Know Act, which grants access to certain instances of excessive use of force, any incident where an officer fires a gun at a person and records relating to sexual misconduct. Before this, most law enforcement misconduct records were closed and typically could not be obtained by the public, or the court system for criminal proceedings.

Instances where the public can access police misconduct records in California include:

● An incident regarding the discharge of a firearm.

● An incident in which use of force by an officer resulted in death or serious injury.

● An incident in which a sustained finding was made by any law enforcement agency or oversight agency that a peace officer or custodial officer engaged in sexual assault involving a member of the public.

● An incident in which a sustained finding was made by any law enforcement agency or oversight agency of dishonesty by a peace officer or custodial officer directly relating to the reporting, investigation, or prosecution of a crime, or directly relating to the reporting of, or investigation of misconduct by, another peace officer or custodial officer, including, but not limited to, any sustained finding of perjury, false statements, filing false reports, destruction, falsifying, or concealing of evidence.

Anything falling outside of these categories is still restricted.

“Most investigations into allegations of police misconduct are still closed under the law,” Stecklow said.

(See more: ACLU Access to CA Police Records).

COLORADO-RESTRICTED

A law passed in 2019, HB 19-1119, opened some police misconduct records that hadn't previously been opened, but the narrow wording restricts its effectiveness. 

Stecklow points out the new law is limited because “it is not retroactive and has language that currently requires requesters to know of specific instances of misconduct, rather than allowing requests for records in general.”

The law opens records "related to a specific, identifiable incident of alleged misconduct involving a member of the public" while the officer is on duty. Denver and Aurora have made misconduct files available but many other departments have not, claiming requests are too vague, says Jeffrey A. Roberts, executive director of the Colorado Freedom of Information Coalition.

Additional police conduct information will be made public under SB 20-2017, the state’s criminal justice reform bill, which goes into full effect in 2023. 

Agencies will be required to release unedited audio and video footage from body and dash cameras of any incident where misconduct is alleged. 

“Other transparency provisions in the bill include the public reporting, in an online searchable database, of extensive information on use of force by law enforcement officers that results in death or serious injuries and the reporting of interactions between officers and the public,” according to the Colorado Freedom of Information Coalition.

CONNECTICUT-RESTRICTED

Police misconduct records in Connecticut are generally public because of the precedent set by the state Supreme Court in 1993 in Perkins V. Freedom of Information Commission, which stated records could be withheld only if they do not pertain to matters of public concern. However a new contract with state troopers limits the access to misconduct records by only making them accessible if a complaint is sustained. Most complaints are not sustained.

According to a study compiled by the ACLU of Connecticut, many departments make it difficult to file a misconduct complaint against an officer and 42% of the departments in the state surveyed by the ACLU suggested that they are not complying with state law requiring public access to complaint policies.

Connecticut is one of the 11 states that provide an integrity bulletin in accordance with the National Decertification Index where it makes the names of these officers public.

However this integrity bulletin doesn’t provide 100% transparency and an investigation by the ACLU of Connecticut found that none of the prosecutors had “Brady lists” of dishonest cops.

WASHINGTON, D.C. - MOSTLY CLOSED

Police misconduct records are mostly closed in D.C., but activists, including the DC Open Government Coalition, are pushing for reform.

The Washington City Paper reports that the D.C. government regularly invokes the “personal privacy” exemptions in Section 2-534(a)(2) of the D.C. Freedom of Information Act. Strong police unions advocate keeping the records private.

DELAWARE-MOSTLY CLOSED

Police misconduct records are closed and exempt from public disclosure in Delaware by both the Delaware Freedom of Information Act and under section 12 of the state’s Law Enforcement Bill of Rights.

According to the Reporter’s Committee for Freedom of the Press, law enforcement organizations in Delaware are sometimes willing to provide general statistics but are usually unwilling to provide specific records in response to information requests.

“Fifteen states have versions of a LEOBOR (Law Enforcement Bill of Rights) statute, but only Delaware’s statute makes internal police investigation records completely confidential forever,” according to the ACLU of Delaware.

FLORIDA-MOSTLY PUBLIC

Law enforcement misconduct records in Florida are generally available under the state’s Freedom of Information Act/Sunshine laws (Florida Statute 119) if the investigation is closed. All active investigations are exempt from public information requests until they are closed or completed.

Misconduct records in Florida are sent to a database that is maintained by the state’s Criminal Justice Standards and Training Commission and this is open for public inspection.

Florida is one of the 11 states that provides an integrity bulletin in accordance with the National Decertification Index where offending officers’ names are public.

GEORGIA-MOSTLY PUBLIC

Under the Georgia Open Records Act, law enforcement misconduct records are available to the public unless the investigation into the misconduct is active and ongoing.

HAWAII-MOSTLY CLOSED

After years of closing records on police misconduct, a new law amending Hawaii’s public record laws passed the state legislature in July 2020. But it allows disciplinary records older than 30 months to be destroyed and denies release of some misconduct complaints where there is lesser or no discipline.

The new law requires county police departments to disclose to the Legislature the identity of an officer who was suspended or discharged and it requires law enforcement departments to provide a yearly update regarding misconduct to the legislature. It also allows public access to information about suspended officers.

The most detailed versions of the disciplinary records of the Honolulu Police Department are destroyed after 30 months, says R. Brian Black, executive director for the Civil Beat Law Center for Public Interest. “The Department does get rid of its more detailed disciplinary documents after 30 months, but it retains a notecard in the file with a summary sentence about the discipline and the nature of the misconduct.”

For lesser punishments - those below firing and suspension - the 2020 law applies a test balancing privacy against the public interest. Privacy considerations often prevail and close records.

IDAHO-MOSTLY CLOSED

Law enforcement misconduct records are closed under Idaho’s Freedom of Information Act requests, according to Section 74-106 of the Idaho Public Records Act.

ILLINOIS-MOSTLY PUBLIC

Most law enforcement misconduct records in Illinois are available because of the precedent set in 2014 in Kalven V. City of Chicago.

Law enforcement agencies in Illinois must provide a “misconduct registry” detailing general information about what an officer was cited for.

In June 2020, in City of Chicago V. Fraternal Order of Police Lodge 7, the Illinois Supreme Court ruled that misconduct records must be preserved and cannot be destroyed every five years, as the Chicago Fraternal Order of Police advocated.

There is a Professional Conduct Database maintained by the state board responsible for certifying and decertifying officers. Local police departments must report to the database when an officer resigns, is fired or is suspended for violating department policy. However a police reform law passed this year closes the database including supporting documents. To get statewide records, a person would have to contact each of the hundreds of police departments.

INDIANA-RESTRICTED

The Indiana legislature passed a bipartisan police reform law this spring, signed by Gov. Eric Holcomb, that provides publication of the names of decertified officers on the website of the Indiana law enforcement academy. But Stecklow says the law allows police agencies to close cases where there is no discipline.

The Indiana Law Enforcement Training Board has revoked 45 licenses since 2007, with only five in the past two years.

Indiana is one of the 11 states that provide an integrity bulletin in accordance with the National Decertification Index where it makes the names of these officers public.

IOWA-MOSTLY CLOSED

Law enforcement records in Iowa are closed but in cases where officers are fired the fact that they were fired can be stated under Iowa Code § 22-7-11.

However, even when records should be public under Iowa’s law, law enforcement agencies find ways to deny them. Newspapers have taken cases to the Iowa Supreme Court because agencies have refused to turn over names and records relevant to the public.

KANSAS-MOSTLY CLOSED

Law enforcement misconduct records are closed under the Kansas Open Records Act (Kansas Statute 45-221). SB270 would make certain law enforcement disciplinary/misconduct records available to the public and prevent the hiring of officers with a history of serious misconduct allegations. It is still in the State’s Senate Judiciary Committee.

Kansas is one of the 11 states that provide an integrity bulletin in accordance with the National Decertification Index, but it does not disclose the names of officers disciplined unless the names are requested.

The Kansas City Star has been fighting these exemptions to obtain records of the Overland Park severance agreement with former officer Clayton Jennison, who shot a 17-year-old to death in 2018 while making a “welfare check” on the youth.

KENTUCKY-RESTRICTED

Access to police misconduct records through the Kentucky Open Records Act is limited and up to the discretion of the law enforcement agency or department involved.

Departments can use KRS § 61.878(1)(a) to claim a general exemption for the records because of privacy concerns for the employee or officer. However, the Kentucky Attorney General has ruled that for the most part, misconduct records should be made public and specified this in the Linda Toler v. City of Muldraugh case in 2004 (03-ORD-213).

An investigation by the Louisville Courier Journal uncovered that police concealed and lied about as many as 750,000 documents in an investigation of sexual misconduct by officers in the “Explorer Scout program,” where police were abusing minors. The Courier Journal sued to uncover these records and a small portion was released. The FBI has since opened an investigation into the Explorer program.

LOUISIANA-MOSTLY PUBLIC

Law enforcement misconduct records are generally public and are not an exception to the Louisiana Sunshine Laws, but some departments may try to deny them based on the State’s privacy protections. In one such case, the city of Baton Rouge tried to deny records to the Capital City Press and the paper appealed the decision.

While misconduct records in Louisiana are mostly public, an investigation by the Southern Poverty Law Center found serious gaps in the collection of other police data by law enforcement agencies, including data dealing with racial profiling.

MAINE-RESTRICTED

Law enforcement misconduct records are available to the public if the investigation is completed or closed. However, investigations that don’t result in discipline or that have findings that are not sustained are not made available to the public.

An investigation conducted by the Bangor Daily News and the Pulitzer Center found that these records often hide misconduct and lack transparency, by not fully describing the incidents in question. Maine only requires that the final findings of an investigation are public, according to their reporting, not the internal investigations leading up to a disciplinary decision.

One of the examples cited by the Bangor Daily is the case of Matthew Shiers, whose public records show that he was fired, but exclude that the internal investigation was prompted by the fact he was charged with aggravated assault, domestic violence and cruelty to animals after fighting with his girlfriend.

MARYLAND-MOSTLY PUBLIC

In April 2021 the state’s House and Senate passed “Anton’s Law,” which will expand access to police misconduct records and increase the use of body cameras in the state, where previously law enforcement investigations and misconduct records were sealed to the public in Maryland. The law, passed over the governor’s veto, also repealed the Law Enforcement Bill of Rights.

Now the public will have access to misconduct records.

MASSACHUSETTS-MOSTLY PUBLIC

new law opens law enforcement misconduct records in Massachusetts, which had previously been closed.

MICHIGAN-RESTRICTED

Police misconduct records are not explicitly secret in Michigan, however they are often denied and considered an unwarranted invasion of privacy under the state’s Freedom of Information Act (Section 15.243.1(a)).

Michigan’s Attorney General Dana Nessel called for the creation of a database that would track police misconduct statewide through the Michigan Commission on Law Enforcement Standards.

The database has not been created.

MINNESOTA-MOSTLY PUBLIC

Law enforcement misconduct records are open to the public under Minnesota’s Public Record Laws.

Minnesota is one of the 11 states that provide an integrity bulletin in accordance with the National Decertification Index where it discloses the names of disciplined officers.

MISSISSIPPI-MOSTLY CLOSED

Law enforcement misconduct records are closed and inaccessible to the public.

MISSOURI-RESTRICTED

On the last day of the session on May 14, 2021, the Missouri Legislature adopted and sent to the governor SB26, which closes misconduct records and adopts a law enforcement bill of rights making it hard to discipline officers. The bill, expected to be signed by the governor, states that the full administrative record of an investigation into misconduct “shall be confidential and not subject to disclosure under Sunshine Law, except by lawful subpoena or court order.” 

The bill also requires local law enforcement to report use of force data to the federal government but redacts the officers’ names by stating, “the personally identifying information of individual peace officers shall not be included in the reports.”

Law enforcement misconduct is usually secret in Missouri, but in 2015 a Missouri court ordered the release of police misconduct records relating to police abuse of World Series tickets in Chasnoff v. St. Louis Board of Police Commissioners. The court said police had no right to privacy in the records. Stecklow explains, “The Chasnoff decision hinged on whether the allegations being investigated could have a criminal element or not; if yes, the records should be released.”

The state’s POST commission does not disclose the names of officers decertified, although it responds to requests for information, Stecklow says. Also information becomes public if an officer contests decertification and appeals to a hearing board.

(See more: Police officers have no constitutional ‘right of privacy’ in records of their official misconduct.)

MONTANA-MOSTLY CLOSED

Police records are generally withheld from the public through Montana Code § 2-6-102 and Article II, Section 10 of the Montana Constitution. The phrasing in section 10 of the Montana constitution, below, “The right of individual privacy is essential to the well-being of a free society and shall not be infringed without the showing of a compelling state interest” allows police departments to argue that most public disclosure of police records does not have a good enough public benefit to justify harming an officer’s individual privacy. However, in some cases, judges have ruled in favor of the records being disclosed under section 9 of the Montana constitution.

Montana is one of the 11 states that provide an integrity bulletin to the National Decertification Index but it does not disclose the names of officers decertified unless the names are requested.

NEBRASKA-MOSTLY CLOSED

Law enforcement misconduct records are secret in Nebraska.

proposed bill that was introduced in the state’s legislature Jan. 20, 2021, would create a police misconduct database, but it has yet to be voted on.

NEVADA-RESTRICTED

Law enforcement misconduct records are restricted in Nevada and it is up to the discretion of individual law enforcement agencies if they are disclosed.

NEW HAMPSHIRE-RESTRICTED

Law enforcement misconduct records were closed in New Hampshire under a personnel exemption to public record requests, but 2020 state Supreme Court decisions limited the use of the personnel exemption and opened some records.

For example, the state’s Supreme Court ruled that lists of police with credibility issues, such as the “Laurie List” of 270 dishonest officers, cannot be kept confidential. But the court still has to determine if release of the names violated the officers’ privacy rights.

NEW JERSEY-RESTRICTED

Law enforcement misconduct records have historically been closed in New Jersey, but the attorney general won a court decision last year that would open the records of the officers who faced discipline for the most serious misconduct.

NEW MEXICO-RESTRICTED

Police departments have routinely used New Mexico Statute 14-2-1 (A)(3) to withhold records from the public. The statute says that some records are matters of opinion, so the department will argue that the disciplinary account is simply one’s opinion regarding the officer and the resulting disciplinary action. But a 2009 state attorney general’s opinion and a 2010 state court decision Cox v. New Mexico Dep’t of Public Safety found that citizen complaints should generally be open.

NEW YORK-MOSTLY PUBLIC

Law enforcement misconduct records became public in New York in August 2020 following nationwide protests after the death of George Floyd at the hands of police.

New York’s police unions strongly opposed this change and five of them united and sued the state when it passed.

(See more: CPR’S INTERVENTION MOTION IN NYPD MISCONDUCT DATABASE CASE.)

They were unsuccessful in preventing the release of records and a database revealed more than three decades of complaints.

Some police departments are still finding ways to make conduct inaccessible, like when the Town of Manlius Police Department in New York attempted to charge the nonprofit organization MuckRock $47,504 to access their records.

NORTH CAROLINA-MOSTLY CLOSED

Law enforcement misconduct records are secret in North Carolina. If an officer is dismissed, demoted, or suspended the disciplinary action and date are publicly available but not the reason. (NCS § 153A-98 and § 160A-168.)

NORTH DAKOTA-MOSTLY PUBLIC

Law enforcement misconduct records are available to the public in North Dakota.

OHIO-MOSTLY PUBLIC

Law enforcement misconduct records are available to the public in Ohio.

OKLAHOMA-MOSTLY CLOSED

Records of police officers can only be publicly accessed if they are records of an officer losing pay, being suspended, being demoted, or being terminated (51 O.S. §24A.8).

OREGON-MOSTLY CLOSED

Law enforcement misconduct records are mostly closed in Oregon and are often denied if there is no discipline, according to Stecklow.

Decertified police officers in Oregon are tracked in a statewide online database maintained by the agency responsible for law enforcement certification. This database was created during a special legislative session in 2020 that called for more police accountability. Oregon does release the names of officers who have been decertified in the state. It began doing this after the death of George Floyd in 2020.

Oregon is one of the 11 states that provide an integrity bulletin in accordance with the National Decertification Index, but it doesn’t disclose the names of officers disciplined unless they are requested.

PENNSYLVANIA-MOSTLY CLOSED

Law enforcement misconduct records are mostly closed in Pennsylvania and their release is up to the discretion of the law enforcement agency, according to Stecklow.

Under the state’s Right to Know Act, a performance rating or review, all documents relating to written criticisms of an employee, grievance material, documents related to discrimination or sexual harassment, information regarding discipline, demotion or discharge contained in a personnel file, arbitration transcripts and opinions, most complaints of potential criminal conduct, and investigative materials, notes, correspondence, videos and reports are all secret and exempt from public record requests (Section 67.708(b) of Pennsylvania’s Right-to-Know Law).

If an officer is discharged or demoted, the fact but not the reason of the disciplinary action will be made public.

In 2020 Gov. Tom Wolf signed a bill into law that created a database to track police misconduct statewide and force agencies to check the database before hiring an officer. Like Illinois, this database is confidential and off limits to the public.

RHODE ISLAND-MOSTLY CLOSED

Law enforcement misconduct records are secret in Rhode Island.

SOUTH CAROLINA-RESTRICTED

The public has restricted access to law enforcement misconduct records in South Carolina.

South Carolina police departments have kept records from being released based on South Carolina statute 30-4-40 saying certain releases of information would be a violation of officers’ privacy. This was pushed back against in Burton v. York Sheriff’s Department, which said that public interest often outweighed the privacy interest of police officer cases. In certain instances, records can be released with the personal identifying information of the officer involved redacted.

SOUTH DAKOTA-MOSTLY CLOSED

Law enforcement misconduct records are secret in South Dakota.

TENNESSEE-MOSTLY PUBLIC

Law enforcement misconduct records are fairly accessible, according to the Tennessee code. In certain cases however, such as Contemporary Media v. Gilless, departments have been able to hold records by arguing that they were part of ongoing or recent criminal investigations. If personal information of an officer is included in requested reports, the officer must be notified.

However, an investigation by WREG in Memphis found that some departments are using an outdated, paper-based system that makes it nearly impossible to receive the requested data, or charges the requester excessive fees.

The July 2020 article said: “In January, WREG asked for records of excessive force and firearm discharge from 2015 to 2019. We were told that would cost nearly $7,500 because there were 24,000 pages of documents and it would take 88 hours to retrieve and redact information. On Feb. 6, we narrowed the timeline to just six months. Now almost six months later, we’re still waiting.”

TEXAS-RESTRICTED, DEPENDING ON CITY

According to research conducted by WNYC radio: “Texas Government Code § 552 generally renders police disciplinary records public. However, many cities in Texas are also covered by Local Government Code § 143, which requires police departments to maintain civil service personnel files on each police officer. Those civil service files are available for public inspection and contain records of disciplinary actions, but only if the officer received at least a suspension or loss of pay. If the only discipline was a 'written reprimand,' the records are instead placed in a confidential internal file.”

UTAH-RESTRICTED

Law enforcement records are public in Utah unless their release would interfere with an active investigation.

Utah is one of the 11 states that provide an integrity bulletin in accordance with the National Decertification Index, but it doesn’t disclose the names of officers disciplined in this bulletin.

“Only cases that result in discipline are always public,” Stecklow said. “The rest are subject to a balancing test weighing privacy and public interests, and which can often come down on the side of privacy.”

VERMONT-MOSTLY PUBLIC

Vermont keeps the names of officers about whom complaints are filed secret unless a state board decides to impose discipline, in which case the names and details are public.

Records containing the names of officers who engaged in misconduct should be released if the public interest outweighs the privacy interest of the officer, the state courts ruled in Rutland Herald v. City of Rutland, where the court ordered release of the names of officers who had viewed pornography on departmental computers.

Vermont is one of the 11 states that provide an integrity bulletin in accordance with the National Decertification Index, and it makes the names of these officers public.

VIRGINIA-MOSTLY CLOSED

Law enforcement misconduct records are secret in Virginia ( Section 2.2-3705.1 of the Virginia Freedom of Information Act).

WASHINGTON-MOSTLY PUBLIC

Law enforcement misconduct records are available to the public in Washington.

Washington is one of the 11 states that provide an integrity bulletin in accordance with the National Decertification Index, and it makes the names of decertified officers public.

WEST VIRGINIA-RESTRICTED

Similar to Vermont and South Carolina, police departments can withhold records if they would be against privacy interests (statute 29B 1-4), but often courts will rule that public interest outweighs privacy interests of officers.

Charleston Gazette v. Smithers set the precedent that conduct of police officers while they are on the job is public record. This rule is now in the West Virginia Code 29B.

WISCONSIN-MOSTLY PUBLIC

Law enforcement records are generally available to the public in Wisconsin.

Wisconsin Statute § 19.36(10)(b).

WYOMING-MOSTLY CLOSED

Law enforcement misconduct records are kept secret and hidden from the public in Wyoming.

Kallie Cox is the editor-in-chief of The Daily Egyptian, the student newspaper of Southern Illinois University Carbondale and can be reached at Kcox@dailyegyptian.com or on Twitter @KallieECox. William H. Freivogel is a professor at Southern Illinois University and a member of the Missouri Bar. Zora Raglow-DeFranco, a law student at Case Western, contributed to this report.

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