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Arizona public records law applies to metadata

Posted on October 29, 2009July 3, 2025 by Dissent

In a decision that will be welcomed by transparency advocates but may induce handwringing in others, the Supreme Court of Arizona ruled that:

Arizona law provides that “[p]ublic records and other matters in the custody of any officer shall be open to inspection by any person at all times during office hours.” Ariz. Rev. Stat. (“A.R.S.”) § 39-121 (2001). The City of Phoenix denied a public records request for metadata in the electronic version of a public record. We today hold that if a public entity maintains a public record in an electronic format, then the electronic version, including any embedded metadata, is subject to disclosure under our public records laws.

The case is Lake v. City of Phoenix. The full decision is here (pdf).

Hat-tip, How Appealing blog.

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