The Public Records Act "clearly has an administrative purpose -- and seems, in fact, totally administrative and procedural -- for the benefit of the good operation of the state government and its agencies and (unlike FOIA) not for the benefit of individual citizens themselves." The court confirms that text messages are public records, however: "If the documents (texts) were still in the possession of the CIty, even in deleted form, I believe that the City would still have the obligation and duty to retrieve (recover) them. To me it is no different than if paper records were torn up and thown in a trashcan but had not been taken out to the garbage yet."