In Paff v. Galloway Township, 162 A.3d 1046 (N.J. 2017) the Supreme Court of New Jersey unanimously held that electronic metadata, including email fields for “sender,” “recipient,” “date,” and “subject,” pertaining to electronically stored public records are themselves subject to disclosure under New Jersey’s Open Public Records Act (OPRA). The ruling overturned an intermediate appellate court holding that such metadata amounted to the creation of a new document, exceeding the requirements of the OPRA. The Supreme Court reasoned that the OPRA defined a “government record” to include “information stored or maintained electronically” by a New Jersey municipality, and that the metadata sought “was clearly defined and circumscribed; was stored electronically; and by the [defendant] Township’s own admission, could have been produced within minutes.” The court remanded the matter to the trial court to determine whether any statutory exemption in the OPRA would permit the defendant to deny the request at issue, noting the concerns for disruption of public investigations or agency operations and for citizen privacy. But as noted by plaintiff’s counsel, the ruling arguably “makes any [government] document or database fair game. . . . [I]f the government agency can run a report, they have to run it.”