A public record is a record required by law to be made and kept. Public records are typically a record made by a public officer or a government agency in the course of the performance of a duty.
Therefore, obituaries are not public records because they are not required by law to be written and published. A death certificate, on the other hand, is considered a vital notice that must be filed with the state government. It is required by federal law for all states to keep death records.