In State v. City of Clearwater, the Florida Supreme Court held that an e-mail message sent and received over a public agency’s network server “does not automatically become [a] public record[ ] by virtue of” its automatic storage on the server, and that such a record is not encompassed within the statutory definition of “public records,” if an agency employee claims that the content of the e-mail message is “personal.” The Court also agreed with the Second District Court of Appeal by holding that private or personal e-mail messages fall outside the current definition of “public records” in Florida Statutes Section 119.011(1).