Generally, election reports are open to public inspection. There are, however, statutory limitations. T.C.A. § 2-11-202(a)(5) protects reports of election law violation investigations. Additionally, the court of appeals has stated that these reports are public even where they are submitted to the Tennessee Bureau of Investigation as long as the request was made before delivery.
In an opinion addressing the confidentiality of such records, the court promotes the notion that general intent and purpose of the act cannot be subverted by submitting otherwise open records to an exempted agency such as the TBI. Chattanooga Publishing Co. v. Hamilton Co. Election Comm’n, No. E2003-00076-COA-R3-CV, 2003 WL 22469808, at Tenn. Ct. of App. October 31, 2003.