A b s t r a c t Under the common law tradition, access to public records was restricted to those with a "direct and tangible" interest in the information. Challenges to this tradition, however, came from those who considered access to public records a right of citizenship. In the twentieth century, state courts across the country increasingly accepted the right of access to public records, but recognized that this right raised a new set of issues requiring identification of categories of information that could be restricted.