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Public employers have always battled the release of employee documents while complying with the state’s Sunshine Law. Last week, the Missouri Eastern District Court of Appeals provided additional clarification. The Sunshine Law requires government records to be available for inspection and copying unless an exception applies. If a state agency claims an exception, then it has the burden of proving it. The Eastern District Court of Appeals upheld the City of St. Louis police departments’ holding its internal affairs investigation as a personnel disciplinary matter, and therefore upheld the closed record, even though the police department had considered, but not filed, criminal charges against the police officers who arrested the Plaintiff in this case.