Brooke v. Reed

Summary

The Oklahoma Supreme Court held that the Oklahoma Open Records Act does not require a public body to provide email records in their native file format or to disclose embedded metadata when the requested correspondence has been provided in PDF format. The court vacated the Court of Civil Appeals' opinion and affirmed the district court's grant of summary judgment to the Oklahoma State Department of Health. The opinion also concluded that the district court properly considered the agency's summary judgment motions after the evidentiary hearings.

Holdings

1. The Oklahoma Open Records Act does not require a public body to provide copies of email records in their native file format or to produce embedded metadata merely because the records exist in that format.
2. The district court did not err by permitting and ruling on the Department's motions for summary judgment after the evidentiary hearings because the material facts were undisputed and the case presented a pure question of law rather than a completed trial on the merits.

Questions Presented

1. Whether the Oklahoma Open Records Act requires a public body to provide copies of email records in their native file format, including embedded metadata.
2. Whether the district court erred by permitting and ruling on motions for summary judgment after evidentiary hearings concerning injunctive relief.

Disposition

vacated