Background
Ada County Sheriff’s Deputy Tobin Bolter was shot during a Boise traffic stop in April 2024 and died the following day. His body-worn camera recorded the stop, the shooting, bystanders’ and responders’ efforts to aid him, and later scene-management activity.
Garth Gaylord sought the body-camera and dash-camera footage under Idaho’s Public Records Act. The Sheriff’s Office denied the request while related investigations were active. After reviewing the body-camera video in camera, the district court held that it was a public record and ordered its disclosure in full. The sheriff and records technician appealed.
The Court’s Holding
The Idaho Supreme Court held that the entire recording is a public record because it documents an on-duty deputy’s traffic stop and the ensuing law-enforcement and emergency response—matters relating to the conduct or administration of public business.
But the Court vacated the judgment and partially reversed the disclosure order. It held that the portion from 00:38 to 08:35 is exempt because release would be an unwarranted invasion of the Bolter family’s personal privacy. Applying Idaho Code section 74-101(17)(a)(ii), the Court adopted a balancing approach under which legitimate, substantial privacy interests are weighed against the public interest in disclosure. The opening segment through 00:37 and the segment from 08:36 to the end must be released. No costs or civil penalty were awarded.
Key Takeaways
- Body-camera footage of an on-duty officer’s traffic stop and the government response to a shooting can be a public record in its entirety.
- Idaho’s privacy exemption requires balancing legitimate and substantial privacy interests against the public’s interest in the information.
- Footage depicting a fatally wounded officer’s immediate aftermath and lifesaving efforts may be withheld to protect surviving family members’ privacy, even when other portions must be disclosed.
Why It Matters
The decision establishes Idaho Supreme Court guidance for applying the Public Records Act’s “unwarranted invasion of personal privacy” exemption to law-enforcement investigative materials. Agencies cannot treat sensitive body-camera footage as categorically exempt, but must assess distinct segments and justify withholding under the statutory balancing test.