The plain language of K.S.A. 45-219(a) requires a public agency, upon request, to provide a copy of a public record in the format in which it maintains that record. … Here, if we focus on just an Excel spreadsheet, it can have embedded components that include at least some formulas. Such formulas provide information to show more than just numbers in a cell, but also how those numbers are generated. Hardcopies simply will not work to reproduce accurately such an integrated animal. Plainly, hard copies do not “embed” anything. The only accurate reproduction of an electronic file is a copy of the electronic file, which can easily be provided by, for example, email or thumb drive.
Read the opinion: Roe vs. Phillips County Hospital
