From East County Magazine:
May 2, 2013 (San Diego’s East County) – The First Amendment Coalition has issued advice to public officials in light of a court ruling that found private e-mails used by San Jose city officials to discuss public business must be disclosed if a Public Records Act request is received. The ruling is on appeal and is expected to be upheld, according to legal experts, which would set a statewide precedent.
“Public officials beware: The appeal courts’ affirmance is likely to apply to all government emails, not just to emails written after the courts’ decision," the First Amendment Coalition warns. "That means the emails you write today, using a private account to discuss government business, will have to be disclosed in the future.”