Energy Policy Advocates v. Ellison

The appellate court found that the attorney general could only withhold "private data on individuals" under the Minnesota Government Data Practices Act (MGDPA) to the extent that documents contained "data on individuals." The appellate court also ruled that the district court erred by failing to conduct an in camera review to determine whether documents were collected as part of an inactive or active investigation and by concluding that attorney-client privilege applied based solely on the respondents' "general descriptions of categories of documents." In addition, the appellate court held that the common interest doctrine did not provide an exception to the MGDPA's disclosure requirements, and that even if it did, the exception would apply to only documents withheld pursuant to attorney-client privilege, not the work-product doctrine.