From the Fayetteville Observer (3/26/11): E-mails are a common and efficient way to communicate in the workplace, and it's no different for public employees.
Electronic missives, long memos and spreadsheets are all open to public inspection if they involve the government’s business.
The N.C. Press Association has long taken the position that it’s not how e-mails are sent but their content that determines whether they are public records. An e-mail discussing government business is public, even if it’s sent on someone’s home computer or private cell phone.
On the other hand, a public employee using his work e-mail to ask his wife if he should pick up a gallon of milk on the way home is not public, according to the Press Association.