i202 Fall 2009 School of Information, UC Berkeley

The Arizona Supreme Court ruled in Lake v. City of Phoenix that as law dictates for public records disclosure (as it does in Phoenix), when public records are requested, even if they are in an electronic format, they must be provided and must include the metadata. From the decision:

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.

Summary available here. I feel like the court is saying through this ruling that metadata, at least when attached to public records, is part of the content.