North Carolina
North Carolina Public Records Law and Body-Camera Access (2026)
Independently fact-checked against primary sources (last audited August 4, 2026). · Law checked current as of August 9, 2026. · 6 primary sources cited on this page. How we verify our legal content

North Carolina's Public Records Law, Chapter 132 of the General Statutes, is generous on eligibility and unusually quiet on timing: any person may request records, no purpose may be demanded, and copies must be furnished "as promptly as possible," with no day-count attached. Police video is different, and it is the part of North Carolina law worth reading closely before you file.
What Chapter 132 covers
Section 132-1 defines public records expansively: documents, papers, letters, maps, books, photographs, films, sound recordings, magnetic or other tapes, electronic data-processing records, artifacts, or other documentary material, regardless of physical form or characteristics, made or received in connection with the transaction of public business by any agency of North Carolina government or its subdivisions.
The statute goes further than most in declaring ownership. Public records are "the property of the people," and agencies hold them on the people's behalf. That framing shapes how North Carolina courts read the exemptions.
The main exemptions include criminal investigation and criminal intelligence records under section 132-1.4, certain personnel records under Chapters 126, 153A, and 160A, trade secrets, and records made confidential by other law. Note the structure of section 132-1.4: it makes investigative records confidential, but it also identifies specific information that remains public, including the time, date, location, and nature of a reported violation, the name and circumstances of an arrest, and the contents of 911 and other emergency call records.
Who can request records
Any person. North Carolina imposes no residency requirement, and the statute is affirmative about motive: "No person requesting to inspect and examine public records, or to obtain copies thereof, shall be required to disclose the purpose or motive for the request."
That sentence is worth quoting in a request letter, because it forecloses the most common informal gatekeeping move.
The timing problem, and how to work with it
North Carolina does not give you a deadline to enforce, and any guide that reports a general number for North Carolina is reporting something the statute does not say.
Section 132-6(a) carries both duties in a single sentence: the custodian shall permit any record in the custodian's custody to be inspected and examined at reasonable times and under reasonable supervision by any person, and shall, "as promptly as possible," furnish copies upon payment of any fees prescribed by law. That is the standard. Subsection (b) is the separate no-purpose rule quoted above.
The one fixed number in section 132-6 has a narrow home: where records are requested in connection with an announced economic development project, the agency must disclose "as soon as practicable, and within 25 business days." That provision exists for a specific category of business-recruitment records and is not a general public-records deadline.
Working within a promptness standard means building your own record of what is reasonable:
- Ask, in the request itself, for an acknowledgment and an estimated completion date.
- Follow up in writing on a fixed schedule, and keep the thread.
- Narrow the scope when the agency tells you volume is the problem, and confirm the narrowing in writing.
- Ask for rolling production of the records already gathered rather than waiting for a complete set.
If the delay becomes a constructive denial, section 132-9 is the remedy, and courts are directed to hear these cases quickly. Build in time for the mandatory mediation step described below, because the court's jurisdiction to order disclosure depends on the requester having complied with it.
What North Carolina can charge
Section 132-6.2 sets a strict actual-cost rule. No public agency may charge a fee for an uncertified copy of a public record that exceeds the actual cost to the agency of making the copy, and "actual cost" is limited to direct, chargeable costs related to the reproduction of a public record as determined by generally accepted accounting principles. Overhead and staff time are not folded into the base rate.
A special service charge is available where the request requires extensive use of information technology resources, or extensive clerical or supervisory assistance, or where producing the record in the requested format requires greater information technology use than the agency's established standard. Such a charge must be reasonable and based on the actual cost incurred.
Two additional points from the same section matter. First, nothing requires an agency to respond to a request by creating or compiling a record that does not exist. Second, a requester who believes a fee is unfair may ask the State Chief Information Officer to mediate the dispute, which is a low-cost, non-judicial option that few requesters know about.
North Carolina has no public-interest or indigency fee waiver. The actual-cost ceiling is the protection. As of August 2026, the most effective way to control cost is to request records in the electronic format the agency already maintains, which avoids per-page copying altogether.
How to file a North Carolina request
There is no statewide portal. Requests go to the custodian of the records at the agency that holds them: the city or county clerk, the university public records office, the state agency's general counsel or records officer.
The statute does not require a written request, and inspection can be arranged informally. Put it in writing anyway. A written request establishes what you asked for and when, which is the evidence a court needs if you later have to argue that production was not "as promptly as possible."
Identify the office, the record type, and a date range, cite section 132-6, note that no purpose need be stated, ask for the records in their native electronic format, and ask for a cost estimate and an estimated completion date. Our free records request generator will assemble that for North Carolina, and our guide to filing a records request covers the federal FOIA path.
If North Carolina denies your request
Section 132-9 provides the remedy: any person who is denied access to public records for inspection and examination, or who is denied copies, may apply to the appropriate division of the General Court of Justice for an order compelling disclosure or copying.
Four features of that section are worth knowing before you file:
- Mediation is a jurisdictional gate, not an option. Section 132-9(a) is phrased affirmatively: a person denied access may apply to the appropriate division of the General Court of Justice for an order compelling disclosure or copying, "and the court shall have jurisdiction to issue such orders if the person has complied with G.S. 7A-38.3E." Compliance with that mediation statute is therefore a precondition to obtaining an order, not an alternative you can decline in favor of going straight to a judge. Start it early, and keep the documentation that shows you complied.
- Priority. Actions brought under section 132-9 are set down for immediate hearing, and subsequent proceedings, including appeals, are accorded priority by the trial and appellate courts.
- Attorney fees are mandatory for a prevailing requester, subject to a shield. Section 132-9(c) says the court "shall allow" a party seeking disclosure who substantially prevails to recover its reasonable attorney fees attributable to those records, and section 132-9(d) uses the same mandatory language for an assessment against "the person or persons instituting the action" where the court determines the action "was filed in bad faith or was frivolous." That sanction reaches the party who filed, not anyone who merely took part. The discretion sits in the shield rather than in the award: fees may not be assessed against the governmental body or governmental unit if the court finds it acted in reasonable reliance on (1) a judgment or order of a court applicable to that governmental unit or body, (2) the published opinion of an appellate court, an order of the North Carolina Business Court, or a final order of the Trial Division of the General Court of Justice, or (3) a written opinion, decision, or letter of the Attorney General. That three-item shield runs to the body, not to individuals: a public employee or public official is covered by a separate clause instead, which bars an order against that person in any case where they sought the advice of an attorney and followed it. Read both before you assume a denial is indefensible, because a body that acted in reasonable reliance on a matching authority is protected even if it loses.
- Personal liability. The court may order that the fees be paid personally by the public official or employee, rather than by the unit, where that person knowingly or intentionally "committed, caused, permitted, suborned, or participated in" a violation of the Article. That is the provision that gets an individual custodian's attention.
Body-camera and dash-camera video: a separate legal track
This is the most important thing to understand about North Carolina records access, and it trips up requesters who assume a video is just another record.
Section 132-1.4A governs recordings made by body-worn cameras, dashboard cameras, and other devices used by law enforcement. Those recordings are expressly not public records under Chapter 132 and not personnel records. They exist in their own procedure, and every element of that procedure is narrower than the general track.
Who may request disclosure. Section 132-1.4A(c) limits disclosure to a person whose image or voice is in the recording, or to a personal representative acting for that person: a personal representative of an adult depicted, if that adult has consented to the disclosure; a personal representative of a minor, or of an adult under lawful guardianship; a personal representative of a deceased person depicted; or a personal representative of an adult who is incapacitated and unable to provide consent. Nothing in that ordinary track requires the adult's consent to be in writing; the notarized form belongs to the death and serious-bodily-injury procedure described below. "Personal representative" is defined broadly in subsection (a)(5): a parent, court-appointed guardian, spouse, or North Carolina licensed attorney of the person depicted, and where that person has died, also the personal representative of the estate, the surviving spouse, a parent, an adult child, a North Carolina licensed attorney, or the parent or guardian of a surviving minor child. A surviving spouse, parent, or adult child therefore qualifies in their own right, and the category is not limited to whoever administers the estate. A member of the public with no connection to the incident is not on that list, and would instead have to seek a court order for release, a different and heavier procedure.
How the request is made. A written request goes to the head of the custodial law enforcement agency and must state the date and approximate time of the activity captured, or otherwise identify it with reasonable particularity.
Death and serious bodily injury go to court, not to the agency head. This is the carve-out that matters most, and it is easy to miss. Subsection (c) provides that recordings depicting a death or serious bodily injury "shall only be disclosed as provided in subsections (b1) through (b3)." In that track the requester submits a signed and notarized form, developed by the Administrative Office of the Courts, to the head of the law enforcement agency. Within three business days the agency must file a petition in superior court in a county where any portion of the recording was made and deliver the petition and the recording to the senior resident superior court judge or a designee. There is no filing fee. The court conducts an in-camera review and enters an order within seven business days directing that the recording be disclosed without redaction, disclosed with redaction, disclosed at a later date, or not disclosed. Disclosure ordered this way happens in a private setting, and the person viewing it may not record or copy it. A family seeking footage of a relative's death is on this track, not the ordinary one.
The agency's decision on every other recording. For recordings that do not depict a death or serious bodily injury, the agency head decides whether to disclose, considering statutory factors such as whether the recording contains information that is confidential or exempt, whether disclosure would reveal highly sensitive personal information, harm someone's reputation, jeopardize a person's safety, or create a serious threat to the fair administration of justice, and whether confidentiality is necessary to protect an active investigation.
The court step for agency denials. If the agency denies a request decided under subsection (d), or does not act within three business days, the requester may apply to superior court in a county where any portion of the recording was made for review. And here is the sharpest difference: the court may order disclosure only if it finds that the agency abused its discretion. That is a far more deferential standard than the de novo review a general public records case gets.
No attorney fees. In an action under section 132-1.4A, the court may not award attorney fees to any party. Compare that with section 132-9, where a requester who substantially prevails may recover fees. The economics of a video case are therefore completely different, and a requester generally has to fund the effort themselves.
Cost. The agency may charge a fee for a copy not exceeding the actual cost of making the copy.
The practical takeaways: identify yourself as a person depicted in the recording if you are one, since that is the eligibility gate; state the date, time, and location precisely; track the three-business-day mark; and understand from the outset that the standard on review of an agency denial is abuse of discretion, not a fresh look at whether the video should be public. If the recording depicts a death or serious bodily injury, use the notarized form instead and expect a judge, not the agency head, to decide.
Note that the 911 call that generated the incident sits on the general track, not the video track, and section 132-1.4(c) keeps the contents of emergency call records public. Our guide to 911 calls and public records covers that in detail.
Records outside Chapter 132
North Carolina birth and death certificates are vital records administered by the Department of Health and Human Services' Vital Records office and by county registers of deeds, with certified copies limited to people who can show a direct interest. A Chapter 132 request is not the route; see our North Carolina death records guide.
Court files are governed by the judicial branch, and land records run through the register of deeds in each county rather than through a records request.
The rules above reflect N.C. Gen. Stat. Chapter 132, including sections 132-6, 132-6.2, 132-9, 132-1.4, and 132-1.4A, as published by the North Carolina General Assembly and reviewed in August 2026. Agency fee schedules and custodian contacts vary. This article is general legal information, not legal advice.
For every state's deadline, fee rules, and appeal route in one place, see our public records laws by state hub.
Frequently Asked Questions
How long does North Carolina have to respond to a public records request?
There is no general statutory deadline. Section 132-6 requires an agency to permit inspection at reasonable times and to furnish copies as promptly as possible. The only fixed clock in that section, twenty-five business days, applies to records requested in connection with an announced economic development project, not to ordinary requests. Build your own record of follow-ups so you can show that production was not prompt if you have to go to court.
Do I have to say why I want the records?
No, and the statute is explicit. Section 132-6 provides that no person requesting to inspect and examine public records, or to obtain copies, shall be required to disclose the purpose or motive for the request. North Carolina also imposes no residency requirement.
What can a North Carolina agency charge me?
For an uncertified copy, no more than the actual cost of making the copy, defined as direct chargeable costs of reproduction under generally accepted accounting principles. A special service charge may be added where the request requires extensive information technology resources or extensive clerical or supervisory assistance, and it must be reasonable and based on actual cost. If you believe a fee is unfair, section 132-6.2 lets you ask the State Chief Information Officer to mediate.
Why is body-camera video not a public record in North Carolina?
Because the General Assembly put it in its own statute. Section 132-1.4A states that recordings made by law enforcement body-worn and dashboard cameras are not public records under Chapter 132 and are not personnel records, and it creates a separate disclosure procedure with its own requester eligibility list, its own court petition, and its own standard of review.
Who can request body-camera footage in North Carolina?
A person whose image or voice is in the recording, or a personal representative acting for that person: a personal representative of an adult depicted if that adult has consented to the disclosure, a personal representative of a minor or of an adult under lawful guardianship, a personal representative of a deceased person depicted, or a personal representative of an adult who is incapacitated and unable to consent. Section 132-1.4A(a)(5) defines personal representative broadly, so where the person depicted has died it also covers the surviving spouse, a parent, an adult child, and a North Carolina licensed attorney, not only the representative of the estate. Someone unconnected to the incident is not on that list and would have to pursue a court order for release under a separate procedure. A recording depicting a death or serious bodily injury follows a different route entirely: a signed and notarized request that the agency must take to superior court within three business days.
What happens if the agency refuses to release the video?
If the agency denies the request or fails to act within three business days, you may apply to superior court in a county where the recording was made. The court may order disclosure only if it finds the agency abused its discretion, which is far more deferential than the review a general records denial receives. That route applies to recordings the agency head decides. Where the recording depicts a death or serious bodily injury, the matter is already before a superior court judge under subsections (b1) through (b3), who rules on disclosure after an in-camera review rather than reviewing an agency call. The court may not award attorney fees to any party in that action, so budget accordingly.
Can I recover attorney fees on an ordinary records case?
Yes, if you substantially prevail. Section 132-9(c) says the court shall allow a party seeking disclosure who substantially prevails to recover reasonable attorney fees attributable to those records, and section 132-9(d) says the court shall assess a reasonable fee against the person or persons instituting an action that the court determines was filed in bad faith or was frivolous. That sanction reaches whoever filed the action, not everyone who took part in it. The discretion is in the shield: fees may not be assessed against the governmental body or unit if the court finds it acted in reasonable reliance on a court judgment or order applicable to that unit or body, the published opinion of an appellate court, a Business Court order or a final Trial Division order, or a written Attorney General opinion, decision, or letter. That shield covers the body rather than individuals; a public employee or official is instead protected by a separate clause barring an order against them where they sought an attorney's advice and followed it. The court may order fees paid personally by an official who knowingly or intentionally committed, caused, permitted, suborned, or participated in a violation. None of that fee exposure exists in a section 132-1.4A video case.
Can the agency make me pay for staff time?
Not as part of the base copy fee. Section 132-6.2 limits the fee for an uncertified copy to actual reproduction cost determined under generally accepted accounting principles. Staff time enters only through the special service charge, which requires the request to involve extensive information technology resources or extensive clerical or supervisory assistance, and which must itself be reasonable and cost based.
Does North Carolina have to create a record for me?
No. Section 132-6.2 provides that nothing in it requires a public agency to respond to a request for a copy of a public record by creating or compiling a record that does not exist. Ask for records the agency already keeps, such as an existing report, database export, or email, rather than for a summary or an answer to a question.
Updates
Corrected the body-camera section to add the mandatory superior court track for recordings depicting a death or serious bodily injury, broadened the list of family members who may request footage, removed a misquotation of the records-enforcement statute, and narrowed the descriptions of the bad-faith fee sanction and the reasonable-reliance shield to match the statutory text.
Governing law re-checked for recent changes
Independently fact-checked against the cited primary sources
The Law Behind This Article
This article rests on the statutory provisions below, held in our own legal record and retrieved from the official source. Tap a section to read the operative text.
North Carolina General Statutes, Chapter 132: Public Records.
§ 132-6Inspection, examination and copies of public recordsIn force
(a) Every custodian of public records shall permit any record in the custodian's custody to be inspected and examined at reasonable times and under reasonable supervision by any person, and shall, as promptly as possible, furnish copies thereof upon payment of any fees as may be prescribed by law. As used herein, "custodian" does not mean an agency that holds the public records of other agencies solely for purposes of storage or safekeeping or solely to provide data processing. (a1) A public agency or custodian may satisfy the requirements in subsection (a) of this section by making public records available online in a format that allows a person to view the public record and print or save the public record to obtain a copy. If the public agency or custodian maintains public records online in a format that allows a person to view and print or save the public records to obtain a copy, the public agency or custodian is not required to provide copies to these public records in any other way. (b) No person requesting to inspect and examine public records, or to obtain copies thereof, shall be required to disclose the purpose or motive for the request.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at ncleg.gov
Cited in 31 court opinions in our collectionLatest citing opinion in our collection: 2026
In the courts (editorial summary, independently checked):News and Observer Publishing Co. v. Poole (1992) held SBI reports submitted to a university commission became commission records subject to the Public Records Law, whose custodian duty section 132-6 states. Virmani v. Presbyterian Health Services Corp. (1999) stated a custodian has no discretion to prevent inspection and copying.
Opinions citing this section in our collection:
- Virmani v. Presbyterian Health Services Corp. (Supreme Court of North Carolina 1999, 350 N.C. 449)✓A newspaper sought sealed medical peer review documents from a doctor's lawsuit. The court held the exhibits he filed with his complaint entered the public domain and had to be unsealed for inspection and copying, while materials given only to the judge were not public records.
- News and Observer Publishing Co. v. Poole (Supreme Court of North Carolina 1992, 330 N.C. 465)✓A newspaper sought records of a university commission that used SBI agents to investigate a basketball program. The court held the SBI reports became commission records once submitted and lost the SBI exemption, and it refused to add a deliberative process privilege to the act.
- Piedmont Publishing Co. v. City of Winston-Salem (Supreme Court of North Carolina 1993, 334 N.C. 595)✓A newspaper sought copies of recordings police gathered in a criminal investigation that were part of the State's file in a pending prosecution. The court held the criminal discovery article is the more specific statute and controls, so section 132-6 gave the newspaper no access.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 132-9Access to recordsIn force
(a) Any person who is denied access to public records for purposes of inspection and examination, or who is denied copies of public records, may apply to the appropriate division of the General Court of Justice for an order compelling disclosure or copying, and the court shall have jurisdiction to issue such orders if the person has complied with G.S. 7A-38.3E. Actions brought pursuant to this section shall be set down for immediate hearing, and subsequent proceedings in such actions shall be accorded priority by the trial and appellate courts. (b) In an action to compel disclosure of public records which have been withheld pursuant to the provisions of G.S. 132-6 concerning public records relating to the proposed expansion or location of particular businesses and industrial projects, the burden shall be on the custodian withholding the records to show that disclosure would frustrate the purpose of attracting that particular business or industrial project.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at ncleg.gov
Cited in 28 court opinions in our collectionLatest citing opinion in our collection: 2025
Opinions citing this section in our collection:
- Charns v. Brown (Court of Appeals of North Carolina 1998, 129 N.C. App. 635)“…hat an action to compel disclosure of public records under N.C. Gen. Stat. § 132-9 is not a civil action but a special pr…”
- Shella v. Moon (Court of Appeals of North Carolina 1997, 125 N.C. App. 607)“…Compelling Disclosure of Public Records” in accordance with N.C. Gen. Stat. section 132-9. Subsequently, this Court issued an opi…”
- State Employees Ass'n of North Carolina, Inc. v. North Carolina Department of State Treasurer (Court of Appeals of North Carolina 2009, 200 N.C. App. 722)“…endants to produce the requested records to Plaintiff under N.C. Gen.Stat. § 132-9(a). In March 2008, Defendants filed an…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 132-6.2Provisions for copies of public records; feesIn force
(a) Persons requesting copies of public records may elect to obtain them in any and all media in which the public agency is capable of providing them. No request for copies of public records in a particular medium shall be denied on the grounds that the custodian has made or prefers to make the public records available in another medium. The public agency may assess different fees for different media as prescribed by law. (b) Persons requesting copies of public records may request that the copies be certified or uncertified. The fees for certifying copies of public records shall be as provided by law. Except as otherwise provided by law, no public agency shall charge a fee for an uncertified copy of a public record that exceeds the actual cost to the public agency of making the copy. For purposes of this subsection, "actual cost" is limited to direct, chargeable costs related to the reproduction of a public record as determined by generally accepted accounting principles and does not include costs that would have been incurred by the public agency if a request to reproduce a public record had not been made.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at ncleg.gov
Cited in 2 court opinions in our collectionLatest citing opinion in our collection: 2019
Opinions citing this section in our collection:
- Ochsner v. N.C. Dep't of Revenue (Court of Appeals of North Carolina 2019)“…agency must produce only the records which already exist. N.C. Gen. Stat. § 132-6.2(e) (“Nothing in this section shall be…”
- Brooksby v. North Carolina Administrative Office of Courts (Court of Appeals of North Carolina 2016, 248 N.C. App. 471)“…you prefer to do this yourself then we request pursuant to N.C. Gen. Stat. § 132-6.2, that these records be provided in dig…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 132-1.4ALaw enforcement agency recordingsIn forcecited in 5 of our articles
(a) Definitions. - The following definitions apply in this section: (1) Body-worn camera. - An operational video or digital camera or other electronic device, including a microphone or other mechanism for allowing audio capture, affixed to the uniform or person of law enforcement agency personnel and positioned in a way that allows the camera or device to capture interactions the law enforcement agency personnel has with others. (2) Custodial law enforcement agency. - The law enforcement agency that owns or leases or whose personnel operates the equipment that created the recording at the time the recording was made. (3) Dashboard camera. - A device or system installed or used in a law enforcement agency vehicle that electronically records images or audio depicting interaction with others by law enforcement agency personnel. This term does not include body-worn cameras. (4) Disclose or disclosure. - To make a recording available for viewing or listening to by the person requesting disclosure, at a time and location chosen by the custodial law enforcement agency. This term does not include the release of a recording. (5) Personal representative.
Official text (excerpt) · last checked 2026-08-31 · Read the full text in our law library · Verify at ncleg.gov
Also relied on in: North Carolina Laws on Recording Police: Rights, Body Cameras, and HB 972, North Carolina Recording Laws (2026): One-Party Consent Rules, North Carolina Police Body Camera Laws: Access & Court Petitions
§ 132-1.4Criminal investigations; intelligence information records; Innocence Inquiry Commission recordsIn forcecited in 3 of our articles
(a) Records of criminal investigations conducted by public law enforcement agencies, records of criminal intelligence information compiled by public law enforcement agencies, and records of investigations conducted by the North Carolina Innocence Inquiry Commission, are not public records as defined by G.S. 132-1. Records of criminal investigations conducted by public law enforcement agencies or records of criminal intelligence information may be released by order of a court of competent jurisdiction. (b) As used in this section: (1) "Records of criminal investigations" means all records or any information that pertains to a person or group of persons that is compiled by public law enforcement agencies for the purpose of attempting to prevent or solve violations of the law, including information derived from witnesses, laboratory tests, surveillance, investigators, confidential informants, photographs, and measurements. The term also includes any records, worksheets, reports, or analyses prepared or conducted by the North Carolina State Crime Laboratory at the request of any public law enforcement agency in connection with a criminal investigation.
Official text (excerpt) · last checked 2026-09-08 · Read the full text in our law library · Verify at ncleg.gov
Cited in 36 court opinions in our collectionLatest citing opinion in our collection: 2026
In the courts (editorial summary, independently checked):Gannett Pacific Corp. v. North Carolina State Bureau of Investigation (2004) held SBI criminal investigation records are not public records under G.S. 132-1.4(a), yet a requester remains entitled to the items subsections (c) and (k) list. In Re Investigation Into Death of Cooper (2009) applied subsection (k) to sealed search warrants.
Opinions citing this section in our collection:
- Gannett Pacific Corp. v. North Carolina State Bureau of Investigation (Court of Appeals of North Carolina 2004, 164 N.C. App. 154)✓Broadcasters sought closed SBI files on a fatal county jail fire; the court held G.S. 132-1.4(a) plainly makes criminal investigation and intelligence records non-public, with no exception once an investigation is finished, though subsection (c) and (k) items stayed available.
- In Re Investigation Into Death of Cooper (Court of Appeals of North Carolina 2009, 200 N.C. App. 180)✓News companies moved to unseal search warrants from the Nancy Cooper homicide investigation; the court held G.S. 132-1.4(e) did not reach returned search warrants, but found no abuse of discretion in sealing them under subsection (k), which permits withholding by court order.
- McCormick v. Hanson Aggregates Southeast, Inc. (Court of Appeals of North Carolina 2004, 164 N.C. App. 459)✓A quarry owner requested Raleigh city attorney records about zoning enforcement on its land; the court held that office is a public law enforcement agency under G.S. 132-1.4(b)(3), that the exception is not limited to open investigations, and that in camera review was required.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: North Carolina Warrant Search: How to Check If You Have a Warrant (2026), North Carolina Police Reports: How to Get a Crash or Incident Report
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Sources and References
- N.C. Gen. Stat. section 132-6 - inspection and copies as promptly as possible, no purpose or motive may be required(ncleg.gov).gov
- N.C. Gen. Stat. section 132-6.2 - copy fees limited to actual cost, special service charges, and fee mediation by the State Chief Information Officer(ncleg.gov).gov
- N.C. Gen. Stat. section 132-1.4A - law enforcement agency recordings, who may request disclosure, and superior court review under an abuse of discretion standard(ncleg.gov).gov
- N.C. Gen. Stat. section 132-9 - action to compel disclosure, priority hearing, and attorney fees(ncleg.gov).gov
- N.C. Gen. Stat. section 132-1.4 - criminal investigations and criminal intelligence records(ncleg.gov).gov
- North Carolina Department of Justice - public records guidance for state and local agencies(ncdoj.gov).gov