The Arizona Supreme Court ruled on Thursday, October 29, 2009, in Lake vs. City of Phoenix, CV-09-0036-PR that:
Arizona law provides that public 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.