In a recent case, Forrest v. Erie City, AP 2023-1701 (Sept. 28, 2023), the Erie City responded to a demand for a record of all licensed and registered rental properties within the city, a request initially made in Excel format, by providing a PDF version of the requested Excel spreadsheet. The appellant contended that the PDF given by the city was a nonsensical, unreadable, and unworkable document of 1,600 pages.
This case reiterates the prerogative of local agencies to respond to requests for information in a format of their choice, even if that differs from the requested format. It highlights an important aspect of information provision, such as the dynamic between the nature of the requested information, the capabilities of the providing body, and the formats that best reflect effective communication of the requested information.
While transformation of formats, from Excel to PDF in this instance, might lead to a loss or distortion of information, it may sometimes be necessary from the agency’s perspective for ease of provision or legal compliance. However, the provision format must still be readable and useable, as underscored by the appellant’s argument in this case.
Conclusively, this case, amidst many, contributes to the ongoing discussion about the rights, duties, and limitations of public agencies in responding to requests for information.