The Wisconsin Court of Appeals has upheld a lower court's decision denying Matthew Kleinhans' request for an unredacted email from the Lincoln County Sheriff's Office. This ruling, issued on November 3, 2026, affects individuals seeking public records and highlights the balance between public safety and transparency.

Kleinhans, representing himself, sought the email to identify a person who reported him for allegedly possessing a firearm at the Lincoln County Courthouse. The court's decision underscores the complexities of public records law and the importance of protecting the identities of individuals who report potential security threats.

Background

The dispute began on November 27, 2023, when law enforcement searched Kleinhans at the Lincoln County Courthouse after receiving a tip about a possible firearm in his backpack. Following the search, which did not yield a weapon, Kleinhans filed a public records request for the email that initiated the investigation. The Sheriff’s Office provided a redacted version of the email, omitting the name of the tipster.

The Sheriff justified the redaction under Wisconsin Statutes, stating that revealing the reporter’s identity could deter future reports of potential threats. Kleinhans submitted a second request for the same email, but the Sheriff reiterated the redaction, citing similar reasons. Additionally, Kleinhans sought courthouse surveillance video related to the incident, but the Sheriff withheld this footage as well, claiming it could expose security vulnerabilities.

After his requests were denied, Kleinhans filed a petition for a writ of mandamus in the circuit court, asking the court to compel the Sheriff to release the unredacted email. The Sheriff moved for summary judgment, asserting that Kleinhans had no legal right to the unredacted document and that the redaction was appropriate.

The Ruling

The Court of Appeals affirmed the lower court's ruling, stating that the Sheriff properly applied the balancing test required under public records law. The court noted, "the public interest in persons being able to notify law enforcement of potential security issues without fear of retribution or retaliation outweighs the public interest of disclosure of personally identifying information of a source of security intelligence."

The court found that Kleinhans failed to establish a clear legal right to the unredacted email, which is a necessary condition for a writ of mandamus. The judges emphasized that the facts surrounding the case were undisputed and that the Sheriff had a valid basis for withholding the information.

Additionally, the court addressed Kleinhans' claims of judicial bias, concluding that he did not provide sufficient evidence to support his allegations. The judges noted that the circuit court had conducted a thorough review of the case and had not acted with bias against Kleinhans.

Impact

This ruling has significant implications for public records requests in Wisconsin. It reinforces the principle that the identities of individuals providing tips to law enforcement can be protected to encourage reporting of potential threats. The decision also clarifies the application of the balancing test under Wisconsin's open records law, which weighs public interest against the need for confidentiality in certain cases.

Individuals and organizations seeking public records may need to consider the potential for redactions, especially in cases involving sensitive information or safety concerns. The ruling serves as a reminder that while transparency is important, there are circumstances where privacy and safety take precedence.

What's Next

Kleinhans has the option to appeal the decision to the Wisconsin Supreme Court, although it is unclear if he will pursue this route. There are no related cases pending that could directly influence this ruling. The outcome of this case may also prompt further discussion on public records laws and the balance between transparency and security.