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 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."