INTRODUCTION: The most important developments in the nature of the public employment relationships have been those which increased the personal accountability of public employees. Civil service systems, particularly in regulatory areas, have been criticized as insulating public employees and removing incentives to perform their public duties.' Recent judicial decisions developing tort liability of public employees and the recent action of the United States Congress in passing the Freedom of Information Act [FOIA) sanctions provision portend future use of the concept of personal accountability as a means of controlling administrative abuse. Throughout deliberation on the FOIA sanctions provision, opposition to the provision was premised upon the rationale of cases limiting the personal liability in tort of public employees. Because the provision rejects these arguments by implication, a reassessment of the tort liability of public employees is appropriate. Moreover, tort liability and the FOIA sanctions provision raise questions concerning the nature of future accountability schemes.