Lake v. City of Phoenix

Summary

The Supreme Court of Arizona held that when a public entity maintains a public record in electronic format, the electronic version, including embedded metadata, is subject to disclosure under Arizona's public records law. The court also held that a superior court generally may not decline jurisdiction over a properly filed special action seeking access to public records. The judgment was vacated in part and remanded.

Holdings

1. When a public entity maintains a public record in electronic format, the electronic version of the record, including embedded metadata, is subject to disclosure under Arizona's public-records law.
2. When a person properly invokes the special-action procedure under A.R.S. § 39-121.02(A) to challenge denial of access to public records, the superior court lacks discretion to deny jurisdiction and must decide the case on its merits.

Questions Presented

1. Whether an electronic version of a public record, including embedded metadata, is subject to disclosure under Arizona's public-records law.
2. Whether the superior court had discretion to deny jurisdiction and relief on a special action brought under A.R.S. § 39-121.02 to challenge denial of access to public records.

Disposition

vacated