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.

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."