Citizens for Fauquier County v. Warrenton (COA)

The Court of Appeals rules that a city/town invoking the working papers and correspondence exemption (in particular, the correspondence part), cannot invoke it on behalf of both the city/town mayor AND the city/town manager (or other executive officer). The city/town must choose between the two. The court also says that the method by which Warrenton selected records for the judge to look at privately to determine if the exemption for working papers applied was inadequate. The trial judge should have required the town to prepare a federal-like Vaughn Index or to pick records randomly or representatively. Whichever method, the main this is that the government has to explain to the judge and other party why and how these records were chosen. Case is remanded for new sampling.