N.J. Supreme Court: logs of government-related emails in private accounts are OPRA records

In Alex Rosetti v. Ramapo-Indian Hills Regional High School Board of Education, decided June 11, 2026, the New Jersey Supreme Court unanimously held that logs of government-related emails housed in officials’ personal accounts are government records under OPRA — while warning that demands for entire personal inboxes are overbroad.

TRENTON — The New Jersey Supreme Court on June 11, 2026, held that logs of government-related emails contained in public officials’ personal email accounts are government records subject to the Open Public Records Act (OPRA), in a unanimous opinion written by Justice Pierre-Louis.

The case is Alex Rosetti v. Ramapo-Indian Hills Regional High School Board of Education, A-72-24 (090375). The dispute began in Bergen County after Rosetti’s January 2023 OPRA request sought, among other items, “email logs of all past and current Board members for all email accounts in which they have conducted or discussed Board of Education matters.” The board produced a redacted log from board-issued accounts but not from personal accounts used for board business. A trial court denied Rosetti’s request; the Appellate Division reversed; the Supreme Court granted certification.

Holding (from the official syllabus / opinion)

Per the Court syllabus and opinion PDF:

• Held: “Logs of government-related emails contained in personal email accounts are government records under OPRA.”
• OPRA’s reach includes communications on personal devices and records in personal accounts when they involve government business, building on Paff v. Galloway Township (email logs as records) and Simmons v. Mercado.
• Board members must search personal accounts (inbox, trash, sent, and other relevant folders) for government-related emails — or use another acceptable method — and produce responsive logs, then submit a certification detailing the searches so a court can assess whether proper searches occurred.
• Rosetti’s request for logs of Board members’ personal email addresses without limiting to government-related messages was overbroad; agencies need not dump entire private inboxes unrelated to public business.

The Court argued the case on Jan. 5, 2026, and decided it June 11, 2026.