The Supreme Court of Arizona held that the City of Phoenix was required to disclose metadata (electronic information concerning the history of an electronic document) pursuant to Arizona's freedom of information law. The City did not contest that the content of the documents constituted a public record, but argued that the metadata did not qualify as a public record subject to disclosure requirements. The Supreme Court reasoned that the metadata in an electronic document is part of the underlying document; it does not stand on its own and when an official uses a computer to make a public record, the metadata forms part of the document as much as words on a page. This analysis was contributed by Right2Info.org.