Director finds South Salt Lake’s records search reasonable in complaint‑records appeal

Misty Woods, the petitioner in appeal 2026‑073, asked the Government Records Office to require the City of South Salt Lake to conduct a broader search for records relating to complaints made against an employee, arguing the city produced additional documents only after the adequacy of its search was challenged.

"The production of additional records after an appeal has begun is not proof that the search was adequate," Woods said, citing an exit interview and an email complaint located only after her statement of facts. She urged the director to order a comprehensive search of HR files, executive records, the mayor’s office, and other likely repositories.

City representative (Brass) said the city’s searches — including targeted email searches and HR checks — found no additional records and that exit interviews and similar materials are typically not maintained in personnel files or disclosed; she also said some communications were transitory and not retained. The city produced two additional items after Woods’s appeal and argued it had performed reasonable searches based on its practices.

Director Pearson reviewed written materials and testimony and concluded the city had conducted additional follow‑up searches after the appeal that cured earlier gaps, concluding the search met GRAMA’s reasonableness standard. He denied the appeal, noting concerns about records management were outside the specific legal question before the office and advising Woods of her right to appeal the written decision to district court.

Why it matters: The ruling underscores that production of additional responsive documents after an initial denial can satisfy GRAMA if the agency conducts a reasonable follow‑up search; it also highlights tensions between public requesters seeking dot‑completeness and agencies relying on standard retention practices for transitory and personnel records.

The director said he will issue a written decision within seven business days and informed parties of appeal rights.