The Arizona Court of Appeals ruled that a government entity cannot avoid disclosing a public document by arguing that the use of encryption to redact nondisclosable information stored in an electronic database constituted creation of a new record.

In a June 22 opinion by Judge Kent Ernest Cattani, the court reversed the lower court's motion to dismiss journalists' statutory special action to compel production of the requested public records, determining that it had erred by concluding their request involved the creation of new records and by dismissing the complaint on that basis.