Does the exemption restricting disclosure of most information in a public employee’s personnel file apply to applicants for public employment?
It depends. Section 9-340C(1) states that the exemption covers “[a]ll other personnel information relating to a public employee or applicant . . . .” In Federated Publications v. Boise City, 128 Idaho 459 (1996), the Idaho Supreme Court distinguished the terms “public official” and “public employee”, holding that applications and resumes submitted by applicants for a vacant city council seat are subject to disclosure. However, in Federated Publications, Inc. v. City of Meridian, Case No. CV OC 97-06708D, the Fourth District ruled that the resumes of applicants for an appointed public office do not need to be disclosed under the public records law.
