Oklahoma Statutes

Okla. Stat. tit. 51, § 24A.20 (2026)

Records in litigation or investigation file - Access

✓ current as of July 2026

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Access to records which, under the Oklahoma Open Records Act, would otherwise be available for public inspection and copying, shall not be denied because a public body or public official is using or has taken possession of such records for investigatory purposes or has placed the records in a litigation or investigation file. However, a law enforcement agency may deny access to a copy of such a record in an investigative file if the record or a true

and complete copy thereof is available for public inspection and copying at another public body. Added by Laws 1988, c. 187, § 7, emerg. eff. June 6, 1988.

Notes of Decisions

Cited in 7 cases (3 in the last 5 years), 1990–2023 · leading case: Oklahoma Assoc. of Broadcasters, Inc. v. City of Norman, 2016 OK 119 (Okla. 2016).

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Oklahoma Assoc. of Broadcasters, Inc. v. City of Norman, 2016 OK 119 (Okla. 2016). · cites it 2× “The District Court must enforce this Court's mandate by either providing the OAB a copy by access to the video in the custody of the clerk or by requiring counsel to provide all opposing counsel copies of the video.”

State Ex Rel. Okla. State Bd. of Med. Licensure & Supervision v. Rivero, 2021 OK 31 (Okla. 2021). · cites it 2× “81 ¶66 Rule-based confidentiality of a record is tied to the concept of an "investigative file" and to application of the Open Records Act, 51 O.S.2011 § 24A.20, which states a public record is not made confidential by merely using the record for "investigatory purposes" or…”

Saxon v. MacY, 795 P.2d 101 (Okla. 1990). · cites it 2× “" [2] The Oklahoma Open Records Act was amended in 1988, after the trial court made its ruling in this case, by adding 51 O.S.Supp. 1988, § 24A.20. This provision states: "Access to records which, under the Oklahoma Open Records Act, would otherwise be available for inspection…”

Good v. Farmers Ins. Co., 2023 OK CIV APP 28 (Okla. Civ. App. 2023). · cites it 3× “12 51 O.S. § 24A.20 51 O.S. § 24A.20 Access to records, which, under the Oklahoma Open Records Act, would otherwise be available for public inspection and copying , shall not be denied because a public body or public official is using or has taken possession of such records for…”

Osu-aj Homestead Med. Clinic v. The Oklahoma Health Auth., 416 P.3d 1082 (Okla. Civ. App. 2018). “1, which provides that Agency "may deny record requests in anticipation of litigation," contradicts the Open Records Act, at 51 O.S. §24A.20, which provides, Access to records which, under the Oklahoma Open Records Act, would otherwise be available for public inspection and…”

Oklahoma Assoc. of Broadcasters, Inc. v. City of Norman, 2016 OK 119 (Okla. 2016). · cites it 3× “51 O.S.2011 § 24A.20. In the present matter, the City argues the record was available for inspection but not copying.”

Good v. Farmers Ins. Co., 2023 OK CIV APP 28 (Okla. Civ. App. 2023). · cites it 3× “They quote 51 O.S. § 24A.20, and claim that the documents are "public records subject to public disclosure.”

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