David E. Roland, Respondent/Cross-Appellant v. St. Louis City Board of Election Commissioners, Jerry Hunter, Paul…

Summary

The Court held that absentee ballot applications become open public records after 8:00 a.m. on the Friday before an election because the governing statutes do not expressly extend confidentiality beyond that time. It also held that ballot envelopes are open records after the voted ballots have been removed, because shared storage with confidential ballots does not create an implied exemption. The Court further held that the election board was not entitled to recover costs for successfully defending against the allegation that its violation was knowing or purposeful, and therefore affirmed the disclosure ruling while reversing the cost award.