Defendants do not contest that the video falls within Section 24A.8's scope of being a record of facts. We laid any question of a video being a record to rest in Fabian & Assocs. v. State ex rel. Dep't of Pub. Safety , 2004 OK 67, ¶ 10, 100 P.3d 703, 705, wherein we found that the Act's definition of a record was sufficiently broad to include "any method of memorializing information." City would have the district court and this Court assume that it is a law enforcement agency for purposes of the Act.

Defendants do not contest that the video falls within Section 24A.8's scope of being a record of facts. We laid any question of a video being a record to rest in Fabian & Assocs. v. State ex rel. Dep't of Pub. Safety, 2004 OK 67, ¶ 10, 100 P.3d 703, 705, wherein we found that the Act's definition of a record was sufficiently broad to include "any method of memorializing information." City would have the district court and this Court assume that it is a law enforcement agency for purposes of the Act.

All of these, Appellant contends, constitute “facts concerning arrest.” ¶ 14 In Fabian & Associates, P.C. v. State ex rel. Dept. of Pub. Safety, 2004 OK 67, 100 P.3d 703, the appellant law firm sought declaratory and injunctive relief after being denied, pursuant to an Open Records request, access to recordings of DPS administrative hearings concerning the revocation of drivers licenses. The Supreme Court held the tape recordings of Implied Consent hearings before DPS are “records” as defined by the Act and that DPS is required to provide copies of the recordings for public inspection.

All of these, Appellant contends, constitute "facts concerning arrest." ¶14 In Fabian & Associates, P.C. v. State ex rel. Dept. of Pub. Safety, 2004 OK 67, 100 P.3d 703, the appellant law firm sought declaratory and injunctive relief after being denied, pursuant to an Open Records request, access to recordings of DPS administrative hearings concerning the revocation of drivers licenses. The Supreme Court held the tape recordings of Implied Consent hearings before DPS are "records" as defined by the Act and that DPS is required to provide copies of the recordings for public inspection.

Most of the cases the professor cites concern the definition of "record" under the Act, or some other issue not presented here. See, e.g. , Fabian & Associates, P.C. v. State ex rel. Dep't of Pub. Safety , 2004 OK 67, ¶19, 100 P.3d 703, 707 (holding that tape recordings of revocation hearings "are records subject to public inspection under the Open Records Act"); Citizens Against Taxpayer Abuse, Inc. v. City of Oklahoma City , 2003 OK 65, 73 P.3d 871 (holding that certain financial information of a private corporation in the hands of the city was not a record); Oklahoma Association of Broadcasters, Inc. v. City of Norman , 2016 OK 119, ¶30, 390 P.3d 689, 697 (holding that a prior version of § 24A.8(A), which did not reference "copying," "must be read to allow copying as well as inspection of records"). Other cases concern federal law and have no application here.

"The Legislature's emphatic message to government agencies is, unless otherwise specifically excluded, the public must have prompt and reasonable access to records." Oklahoma Ass'n of Broadcasters, 2016 OK 119, ¶ 15, 390 P.3d 689, citing Fabian & Associates, P.C. v. State ex rel. Dep't of Pub. Safety , 2004 OK 67, ¶¶ 11-12, 100 P.3d 703 ; City of Lawton v. Moore, 1993 OK 168, ¶¶ 5–6, 868 P.2d 690, 704–05. "Because of the strong public policy allowing public access to governmental records, we must construe the Act's provisions to allow access unless an exception clearly applies, and the burden is on the public agency seeking to deny access to show a record should not be made available."