The Oklahoma Bar Journal October 2026

Microsoft Outlook format with metadata included. 10 For instance, the PDF copies of the emails produced contained the contents of the message but did not have the metadata with the technical details about the message such as the information about the sender, recipient, and the date the message was sent. 11 OSDH asserted that providing records in PDF format was a reasonable procedure to pro tect the integrity of the records, as native-format files could be manip ulated and thereby compromise integrity. 12 The Supreme Court agreed with ODSH and stated: “Importantly, the statute also authorizes the public body to estab lish reasonable procedures which protect the integrity and organiza tion of its records and to prevent excessive disruptions of its essen tial functions.” 13 In conclusion, the court held that the plain meaning of “data files” under the ORA does not include metadata and that the ORA does not mandate records to be produced in any specific format, unlike the federal Freedom of Information Act (FOIA). 14 As Brooke vs. Reed illustrates, the definition of record under the ORA is an important aspect to determinewhat records should be

Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff.

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THE OKLAHOMA BAR JOURNAL