Jarron Smith v. Town of Marana, 524 P.3d 254

April 2021: Smith was shot during a public altercation captured on video and witnessed by multiple people; Pima County Attorney declined to charge either participant.
Smith requested police records under A.R.S. § 39-121.01; the Town produced reports, videos, and photos with redactions (names/images of the shooter, a percipient witness, and Smith’s mother).
Smith requested the Town’s records-redaction policies and then sued via statutory special action seeking unredacted records and attorney fees, asserting the redactions improperly withheld public information.
The trial court conducted a Carlson balancing analysis, concluded the Town did not show a sufficient privacy interest, ordered disclosure of the unredacted records, and awarded Smith partial attorney fees and costs.
The Town appealed, arguing: (1) victim-protection statutes (A.R.S. § 13-4401) or privacy interests defeat the presumption of disclosure and (2) the trial court abused its discretion in awarding attorney fees despite the Town’s good-faith redactions.
The Court of Appeals affirmed both the disclosure order and the fee award and granted Smith appellate fees and costs contingent on Rule 21 compliance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the shooter qualifies as a "victim" such that victim-protection statutes flip the burden and limit disclosure	Smith: statutes do not apply; public-records presumption favors disclosure	Town: shooter is a "victim" under § 13-4401 even without arrest/charge, so privacy protections apply	Held: Victim rights attach only on arrest/formal charge (Z.W. v. Foster); § 39-121.04 did not apply, so Town failed to shift the burden
Whether the Town established a privacy/confidentiality interest sufficient under Carlson to justify redacting names/images	Smith: public interest in disclosure of law-enforcement records from a public altercation outweighs speculative privacy harms	Town: participants in uncharged conduct have significant privacy interests; redaction policy justified by stigma, safety, and tech-driven dissemination risks	Held: Generalized/stated harms were too abstract; Town failed to show specific, material probable harm — Carlson balancing favors disclosure
Whether Smith "substantially prevailed" and was entitled to attorney fees under § 39-121.02(B)	Smith: he obtained all requested relief (unredacted records) and thus substantially prevailed	Town: it produced records promptly, acted in good faith, and was largely correct; Smith did not substantially prevail	Held: Smith substantially prevailed (obtained the contested material); trial court did not abuse discretion in awarding and reasonably reduced fees

Carlson v. Pima County, 141 Ariz. 487 (Ariz. 1984) (establishes balancing test weighing privacy/confidentiality against public right of inspection)
Mitchell v. Superior Court, 142 Ariz. 332 (Ariz. 1984) (party seeking nondisclosure must show probability that specific, material harm will result)
Z.W. v. Foster, 244 Ariz. 478 (App. 2018) (victims’ rights under §§ 13-4401 et seq. attach only upon arrest or formal charging)
Hodai v. City of Tucson, 239 Ariz. 34 (App. 2016) (existence of a public record creates a presumption requiring disclosure; right not conditioned on relevance)
American Civil Liberties Union of Ariz. v. Ariz. Dep’t of Child Safety, 251 Ariz. 458 (Ariz. 2021) (framework for determining when a requesting party has "substantially prevailed" for fee awards)