Deliberative process exemption-Alaska
In 1986, in the case of Doe v. Superior Court, the Alaskan Supreme Court ruled that there is a limited "executive" or "deliberative process" privilege in the Alaska Public Records Act that protects communications between the governor and his or her aides about policy matters. This decision related to internal communications about advice, opinions and recommendations. The decision was justified using the separation of powers argument.
In 2000, Gwich'in Steering Committee v. Office of the Governor modified the justification of the deliberative process exemption. The court said the privilege is intended to "protect the mental processes of governmental decisionmakers from interference." .
In 2003, in Fuller v. City of Homer, the court extended the deliberative process to municipalities, given that they met the appropriate requirements. However, the court said that the City of Homer was wrong to claim that it could withhold access to staff documents under the "deliberative processes privilege" as it failed the balancing test established in City of Kenai v. Kenai Peninsula Newspapers.
The Alaska Public Records Act does not mention the deliberative process exemption.