The United States Supreme Court, in McBurney v. Young, ruled that there is no federal constitutional right to public records, and the states have the discretion to limit access to public records to their own citizens. This decision and its impact on the right to obtain public records was explored in a recent article: Chad G. Marzen, “A constitutional right to public information,” available at https://ssrn.com/abstact=3472464
The article also reviews a handful of states that have a state constitutional provision providing a right to access public records, and discusses related issues.
There are some states, such as Delaware, that limit–by statute–access to public records to citizens of that state. The article suggests that greater transparency for governments would be promoted if there was a push for amendments to both the federal and state constitutions that enshrined a right to access public records.