The Supreme Court of Georgia granted certiorari, disapproved of this Court’s interpretation of Bowers , and reversed the judgment of this Court. Campaign for Accountability v. Consumer Credit Research Foundation , 303 Ga. 828, 815 S.E.2d 841 (2018). The Supreme Court held that OCGA § 50-18-72 (a) of the Act does not bar a state agency from publicly releasing records, unless the specific exemption listed in the statute that covers the records at issue expressly prohibits disclosure.

The ORA thus imposes a duty upon "agencies" to produce or to provide access to public records upon a proper request. See OCGA § 50-18-71 (b) (1); Campaign for Accountability v. Consumer Credit Research Foundation, 303 Ga. 828, 830 (2), 815 S.E.2d 841 (2018) ("Government agencies therefore have a duty to disclose public records unless relieved of that duty by a specific exemption or court order.").Gonzalez has not challenged the form of the requests, the method by which they were submitted to her as the custodian of records for her office, or whether the records sought were public records under the ORA.

OCGA § 50-18-71 (a). "Government agencies therefore have a duty to disclose public records unless relieved of that duty by a specific exemption or court order." Campaign for Accountability v. Consumer Credit Research Foundation, 303 Ga. 828, 830 (2) (815 S.E.2d 841) (2018). And the Open Records Act "expressly creates a private right of action to enforce the obligations imposed on persons or agencies having custody of records open to the public under the Act."

The surplusage canon has been adopted in Georgia. See Campaign for Accountability v. Consumer Credit Research Found. , 303 Ga. 828, 834, 815 S.E.2d 841, 846 (2018). "In the absence of words of limitation, words in a statute should be given their ordinary and everyday meaning."