O'Neill v. City of Shoreline
In O'Neill v. City of Shoreline, 145 Wn. App. 913, 187 P.3d 822, 824 (Wash. Ct. App. 2008), a Washington court considered whether specific metadata relating to an e-mail received by a city council member was a public record. 187 P.3d at, 824, P 1.
The court determined that the metadata requested in that case fell within Washington's broad statutory definition of a public record. Id. at 826-27 & nn.17-18, PP 14, 21 (citing Wash. Rev. Code Ann. 42.56.010(2)-(3) (West 2008)) (defining a public record as any document, including "data compilations from which information may be obtained or translated," which contains "information relating to the conduct of government . . . owned, used, or retained by any state or local agency regardless of physical form or characteristics.")