Most states have zero or minimal statutes requiring document retention by public bodies. I know several times I have requested documents from public bodies only

Most states have zero or minimal statutes requiring document retention by public bodies. I know several times I have requested documents from public bodies only to have them immediately throw them in the garbage so that they do not have to disclose them. I even took this to the appellate courts at one point as the argument was whether documents in the garbage are still in the possession of the public body. They said they weren't, I said they were. Courts ruled with the public body. (One of my arguments was also that they can put them in the garbage at the time of the request, write the denial letter, and then pull them back out of the garbage)