Abstract
In Lake v. City of Phoenix, the Arizona Court of Appeals faced the question of whether metadata embedded within an electronic document is accessible under Arizona's public-records statute. Lacking a statutory definition of "public record," the court relied on Arizona common-law definitions from Mathews v. Pyle and Salt River Pima-Maricopa Indian Community v. Rogers. The majority viewed metadata as a mere "by-product" of the underlying public document, and held that it was not independently accessible under the statute. Judge Patricia K. Norris took the opposite view in a dissenting opinion. She argued that metadata was "integral to the original electronic documents," and as such, should be accessible just like a paper copy. This Case Note addresses several post-Lake questions. First, which opinion correctly interprets metadata's relationship to an electronic document? Second, how will Lake impact this issue in other jurisdictions? Finally, how does the federal government's interpretation of metadata requests under the federal Freedom of Information Act (FOIA) compare to the current law in Arizona?
How to Cite
51 Ariz. L. Rev. 517 (2009)
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