Milliron v. Antonakakis

Summary

The Court held that records prepared, maintained, or received by a private contractor while performing services for a public agency are public records subject to the Open Records Act, even when the contractor is also an agency employee. It further held that a request may be served directly on a non-agency custodian of those records, including a private contractor, despite the agency's designation of an open records officer. The Court therefore reversed the dismissal and remanded for further factual determinations concerning the records and Antonakakis's custodial status.