| Case Caption | Case No. | Topics and Issues | Author | Citation / County | Decided | Posted | WebCite |
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Wysong v. Dayton City Hall
| 2025-00002PQ | On objections, the Court overruled Requester’s partial objection to a Special Master’s Report and Recommendation, concluding that the Special Master properly determined that Requester's request for the number of vehicles impounded due to unpaid citations constituted a request for information (which was not an enforceable public-records request) and that Respondent was not required to take any further action on this request. | Sadler | |
5/23/2025
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6/5/2025
| 2025-Ohio-2002 |
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Kearns v. Fairfield Police Dept.
| 2025-00017PQ | Public Records; R.C. 149.43(A)(1)(jj); 149.43(A)(17); a public office improperly redacts video recorded by a body worn camera if the quality of the recording prevents the viewer from being able to perceive allegedly exempted information. | Marti | |
5/7/2025
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6/5/2025
| 2025-Ohio-2003 |
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Wysong v. Dayton City Hall
| 2025-00002PQ | Public Records; R.C. 149.011(G); Quasi-agency doctrine; The exercise of a police power is a governmental function that can support the application of the quasi-agency doctrine. | Marti | |
4/30/2025
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5/8/2025
| 2025-Ohio-1651 |
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Siegel v. Univ. of Cincinnati College of Med.
| 2009-09531JD | Judgment Entry, Plaintiffs’ Objections, Civ.R. 53(D)(3)(b). The Magistrate issued a decision recommending judgment for defendant finding that plaintiffs’ claims were barred by the statute of limitations and that plaintiffs had failed to prove their claims for fraud and spoliation of evidence. Plaintiffs filed objections. The Judge determined that the Magistrate properly determined the factual issues and appropriately applied the law. The Judge overruled the objections and adopted the Magistrate’s decision with modification to reflect the Court’s analysis. Judgment for defendant. | Sadler | |
4/25/2025
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5/22/2025
| 2025-Ohio-1823 |
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Miller v. E. Holmes School Dist.
| 2025-00088PQ | Public Records; 2743.75(D); A requester invoking R.C. 2743.75 must identify the claims he is asserting in the body of his complaint when the attachments reflect multiple public records requests, some of which have apparently been resolved, and some of which may not have been resolved. | Sadler | |
4/22/2025
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5/8/2025
| 2025-Ohio-1652 |
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Miller v. E. Holmes School Dist.
| 2025-00088PQ | Public Records; 2743.75(D); A requester invoking R.C. 2743.75 must identify the claims he is asserting in the body of his complaint when the attachments reflect multiple public records requests, some of which have apparently been resolved, and some of which may not have been resolved. | Marti | |
4/21/2025
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5/8/2025
| 2025-Ohio-1653 |
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Cincinnati Enquirer v. Butler Cty. Sheriff's Office
| 2024-00906PQ | Public Records; R.C. 149.011(G); R.C. 341.01; R.C. 5120.21; Quasi-agency doctrine; Materials that document a public office’s performance of its statutory responsibilities are records; The operation of a jail is a public function supporting the application of the quasi-agency doctrine; R.C. 5120.21 is limited by its own terms to records held by the Ohio Department of Rehabilitation and Correction and does not apply to county jails. | Marti | |
4/11/2025
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5/8/2025
| 2025-Ohio-1650 |
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Mahle Behr Dayton, L.L.C. v. Ohio Bur. of Workers' Comp.
| 2021-00706JD & 2022-00515JD | Civ. R. 56; Motions for Summary Judgment; Fourteenth Amendment; Equal Protection; Rational Basis. This matter came before the Court of Claims on remand per the Tenth District Court of Appeals’ decision in CPC Parts Delivery, LLC v. Ohio Bur. of Workers’ Comp, 2024-Ohio-18. In consolidated matters, Plaintiffs brought claims against Defendant BWC, challenging the methodology applied by Defendant to calculate the amounts of premium rebates issued to certain employers participating in the Ohio Bureau of Workers’ Compensation Fund. Specifically, Plaintiffs alleged that Defendant was unjustly enriched and violated equal protection by utilizing different methods to calculate rebates to employers differently based upon which program of the Compensation Fund that the respective private employer participated in. The Court of Claims granted summary judgment to Defendant on all of Plaintiffs’ claims. On appeal, the Tenth District upheld summary judgment to Defendant on Plaintiffs’ claims of unjust enrichment but reversed the ruling that the Court of Claims did not have subject-matter jurisdiction to consider Plaintiffs’ constitutional equal protection claim. Further, the Tenth District directed the Court of Claims on remand to “undertake a more rigorous analysis of the relevant law as applied to the admissible evidence” in the case with respect to whether Defendant had a rational basis for treating the workers’ compensation programs differently. On remand, the Court of Claims ruled that the evidence established that employers participating in the programs are not in all relevant respects alike or similarly situated. Therefore, Plaintiffs were unable to state their equal protection claim. Furthermore, even if the employers were alike in all relevant respects or similarly situated, the evidence in this matter beget the conclusion that there was a rational reason for the differing treatment of employers based upon the program of the Compensation Fund in which they participated. Defendant’s motions for summary judgment were granted and Plaintiffs’ motions for summary judgment were denied. | Cain | |
4/11/2025
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5/22/2025
| 2025-Ohio-1825 |
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Courtney v. Ohio State Univ. Wexner Med. Ctr.
| 2020-00532JD | Medical negligence; medical malpractice; preponderance of the evidence. In a trial before the Judge, judgment was rendered in favor of defendant for a claim of medical negligence as the evidence presented did not establish by a preponderance of the evidence that defendant’s medical providers breached a duty of care owed to plaintiff. Therefore, the court concluded that defendant was not negligent by failing to diagnose plaintiff sooner or by delaying treatment with steroids. Judgment for defendant. | Sadler | |
4/2/2025
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5/22/2025
| 2025-Ohio-1824 |
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Schaffer v. Ohio State Univ.
| 2024-00876PQ | On objections and motion to strike, the Court overruled Requester’s objections to a Special Master’s Report and Recommendation, denied Requester’s motion to strike, and adopted the Special Master’s Report and Recommendation. The Court determined that, as a lower court within the jurisdiction of the Tenth District Court of Appeals, Doe v. Ohio State Univ., 2024-Ohio-5891 (10th Dist.) is binding precedent that the Court is obligated to follow. | Sadler | |
4/1/2025
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5/8/2025
| 2025-Ohio-1649 |
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AIY Properties, Inc. v. Cleveland
| 2025-00044PQ | Requester failed to provide clear and convincing evidence that the City maintains possession over housing court financial records. Therefore, the Court overruled Requester’s objections. Further, because Requester requested the records from the City and not the housing court, the Court found that the special master correctly applied the Public Records Act and not the Rules of Superintendence in this case. Therefore, the Court overruled Respondent’s objection and adopted the Special Master’s R&R. | Sadler | |
3/12/2025
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4/11/2025
| 2025-Ohio-1294 |
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Schaffer v. Sheets
| 2024-00808PQ, 2024-00828PQ, 2024-00839PQ, 2024-00840PQ, 2024-00841PQ, 2024-00844PQ, 2024-00845PQ, 2024-00846PQ, 2024-00847PQ, 2024-00848PQ, 2024-00849PQ, 2024-00850PQ, 2024-00851PQ, 2024-00852PQ, 2024-00853PQ, 2024-00854PQ, 2024-00855PQ, 2024-00856PQ, 2024-00857PQ, 2024-00858PQ, 2024-00881PQ, 2024-00883PQ, 2024-00889PQ | Public Records; R.C. 2743.75(D)(2); A case may be dismissed pursuant to R.C. 2743.75(D)(2) if the requester has abused the public records laws; Abuse of the public records law is evidenced by excessive numbers of public records requests and/or enforcement actions; Abuse of the public records laws is evidenced by a requester making multiple records requests or filing multiple enforcement actions in rapid succession; Abuse of the public records laws is evidenced by the requester making duplicative records requests or filing duplicative enforcement actions; Abuse of the public records laws is evidenced by the requester using records requests or enforcement actions to demean the public office or its employees; A case may be dismissed pursuant to R.C. 2743.75(D)(2) if the court lacks the capacity to grant the relief requested. | Marti | |
3/11/2025
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3/24/2025
| 2025-Ohio-1007 |
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Kahn v. Dept. of Commerce, Div. of Cannabis Control
| 2024-00703PQ | On Requester’s objections to a report and recommendation, the Court found unpersuasive Requester’s contentions that the requested records existed and were accessible under the “Database Rule,” that the initial request was not overbroad, and that costs should not be assessed against Requester. The Court overruled Requester’s objections and adopted the report and recommendation. | Sadler | |
3/11/2025
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4/11/2025
| 2025-Ohio-1293 |
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Moore v. Ohio Dept. of Rehab. & Corr.
| 2024-00030JD | Motion for summary judgment; Civ.R. 56; defamation; inmate. Plaintiff failed to establish the existence of an issue of material fact as to whether Defendant defamed Plaintiff. Defendant’s motion for summary judgment was granted. | Sadler | |
3/7/2025
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4/10/2025
| 2025-Ohio-1249 |
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Wolfe v. Ohio Dept. of Rehab. & Corr.
| 2024-00499JD | Civ.R. 56; motion for summary judgment; discretionary immunity. Defendant was entitled to summary judgment on plaintiff’s claims relating to defendant’s decision to replace inmate JPay tablets with ViaPath tablets while plaintiff was in the custody and control of defendant because defendant’s decision was based on prison safety and administration considerations and was an executive function that involved a high degree of official discretion, and therefore, defendant was entitled to discretionary immunity. Judgment for defendant. | Sadler | |
3/7/2025
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4/10/2025
| 2025-Ohio-1250 |
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Hastings v. Washington Court House Bldg. & Zoning Dept.
| 2024-00701PQ | Because testimony from a zoning board hearing did not contradict the affidavit that stated that Respondent provided all responsive records, the Court found that Requesters failed to submit clear and convincing evidence that Respondent possesses additional unprovided responsive records. Therefore, Court overruled Requesters’ objections and adopted the Special Master’s R&R. | Sadler | |
3/4/2025
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4/11/2025
| 2025-Ohio-1292 |
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Musgrave v. Yost
| 2023-00670PQ | After court of appeals sua sponte dismissed Requester’s appeal, the Court sua sponte vacated its stay of the case, denied Requester’s motion for an extension of time, denied Requester’s notice seeking dismissal of Respondent’s response to Requester’s objections, and overruled Requester’s objections to a Special Master’s Report and Recommendation. In accordance with the Special Master’s recommendations, the Court found that Requester’s claim for production of records was moot, found that Requester failed to prove a violation of R.C. 149.43(B)(4), rejected Requester’s delay claim, and rejected Requester’s claims about the administration of concealed carry laws. | Sadler | |
2/20/2025
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3/6/2025
| 2025-Ohio-738 |
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Newman v. Greater Columbus Arts Council
| 2024-00619PQ | On objections, the Court overruled Requester’s partial objections to a Special Master’s Report and Recommendation and adopted the Report and Recommendation. The Court found that the Special Master correctly applied the functional equivalency test set forth in State ex rel. Oriana House, Inc. v. Montgomery, 2006-Ohio-4854. In accordance with the Special Master's recommendations, the Court (1) granted Requester’s claim for the production of certain records, (2) ordered Respondent to file a written certification by a specified date that it produced these certain records to Requester, and (3) ordered that Requester was entitled to recover from Respondent the amount of the filing fee of twenty-five dollars and any other costs associated with the action that were incurred by Requester, excepting attorney fees. | Sadler | |
2/18/2025
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3/6/2025
| 2025-Ohio-734 |
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Dunbar v. Ohio Dept. of Transp.
| 2023-00313JD | Magistrate’s Decision, Negligence, Standing Water. Plaintiff failed to prove that defendant negligently designed or constructed the roadway, that defendant had actual or constructive notice of ponding water, or that defendant was willfully blind to the incident location. Judgment was recommended in favor of defendant. | Morris | |
2/14/2025
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3/27/2025
| 2025-Ohio-1056 |
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Schaffer v. Ohio State Univ.
| 2024-00876PQ | Public Records; R.C. 149.43(B)(7)(c)(i) and (iii); R.C. 2743.75(C)(2); Dismissal is only appropriate under R.C. 2743.75(C)(2) if the case both presents an issue of first impression and the issue is of substantial public interest; R.C. 149.43(B)(7)(c)(i) and (iii) explicitly authorize public offices to adopt policies limiting the number of records provided in response to commercially motivated requests. | Marti | |
2/13/2025
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3/6/2025
| 2025-Ohio-735 |
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Bryant v. Ohio Dept. of Taxation
| 2023-00301JD | Civ.R. 56; motion for summary judgment; retaliation; R.C. 4112.02(I); discrimination; adverse employment action; pretext. Defendant was entitled to summary judgment on plaintiff’s claim for retaliation under R.C. 4112.02(I) because plaintiff could not show that she was subject to an adverse employment action necessary to establish a prima facie case of unlawful retaliation. Furthermore, even if plaintiff could establish a prima facie case of unlawful retaliation under R.C. 4112.02(I), there were legitimate, non-discriminatory reasons for plaintiff’s reprimand, suspensions, and termination. Judgment for defendant. | Sadler | |
2/12/2025
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3/27/2025
| 2025-Ohio-1055 |
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Letchford v. Ohio Univ.
| 2023-00539JD | Motion for summary judgment; Civ.R. 56; defamation; statute of limitations. Plaintiff failed to establish the existence of an issue of material fact as to whether Defendant defamed Plaintiff. Defendant’s motion for summary judgment was granted. | Sadler | |
2/12/2025
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3/27/2025
| 2025-Ohio-1057 |
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AIY Properties, Inc. v. Cleveland
| 2025-00044PQ | Public Records; R.C. 149.43(A)(1); Supp. R. 44; Materials that would be court records in the possession of a court, are also public records subject to R.C. 149.43 in the hands of a non-court public office. | Marti | |
2/11/2025
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3/6/2025
| 2025-Ohio-737 |
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Kearns v. Nelsonville Police Dept.
| 2024-00902PQ | Public Records; R.C. 149.43(A)(17)(a); R.C. 149.45(A)(1); The term “primary” connotes more than quantitative or proportional primacy, it also has a qualitative sense; Common usage establishes that something can be “primary” if it is “basic, fundamental” or “essential” to the subject considered; Something can be “primary,” even if it is not the quantitatively predominate feature of the thing considered, so long as it is essential to that thing; A child can be a “primary” subject of a law enforcement recording for purposes of R.C. 149.43(A)(17)(a) if addressing the child’s needs was an essential part of law enforcement’s response to the situation prompting the recording; Telephone numbers are not among the types of information listed in R.C. 149.45(A)(1)’s definition of personal information. | Marti | |
2/6/2025
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3/6/2025
| 2025-Ohio-736 |
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Schaffer v. Ohio State Univ.
| 2024-00815PQ | On objections, the Court sustained, in part, and denied, in part Respondent’s objections to a Special Master’s Report and Recommendation, and the Court found that certain other objections were moot. The Court found that Requester had not sustained his burden to provide clear and convincing evidence that records containing the additional data that Requester sought were created or received by Respondent. Pursuant to R.C. 2743.75(F)(2), the Court rejected the Report and Recommendation. | Sadler | |
1/31/2025
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2/13/2025
| 2025-Ohio-476 |
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Mohler v. Univ. of Toledo Athletic Dept.
| 2023-00630JD | Civ.R. 56; motion for summary judgment; University of Toledo Athletic Department; athletics; negligent misrepresentation; promissory estoppel; negligence; discretionary immunity. In an action where plaintiff was removed from University of Toledo’s women's soccer team, the court found that defendant was entitled to discretionary immunity for the decision to remove plaintiff from the team. Defendant was entitled to summary judgment on plaintiff’s claim for negligent misrepresentation because plaintiff failed to demonstrate that defendant supplied false information to plaintiff that the document plaintiff signed was a National Letter of Intent, and therefore, plaintiff failed to satisfy all the elements of the claim. Defendant was also entitled to summary judgment on plaintiff’s claim for promissory estoppel because the court found that plaintiff’s relationship with University of Toledo was contractual in nature, and therefore, the claim failed as a matter of law. Defendant was further entitled to summary judgment on plaintiff’s claim for negligence as the court concluded that plaintiff failed to state a prima facie case for the claim since plaintiff pointed to no facts or supportive law that would allow the court to conclude that a duty of care existed to provide a safe team environment free from abuse, harassment, ridicule, embarrassment, and hostility. Judgment for defendant. | Sadler | |
1/31/2025
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2/18/2025
| 2025-Ohio-518 |
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Jones v. Ohio State Univ. Wexner Med. Ctr.
| 2023-00266JD | Motion for Summary Judgment, Employment, Age Discrimination, Sex Discrimination. No genuine issues as to any material fact existed regarding plaintiff’s claims for age or sex discrimination. Defendant presented legitimate, non-discriminatory reasons for plaintiff’s termination. Plaintiff failed to establish a prima facie case by presenting facts which demonstrated that defendant’s reasoning for termination of plaintiff’s employment was pretextual. Defendant’s motion for summary judgment was granted. | Sadler | |
1/29/2025
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2/18/2025
| 2025-Ohio-517 |
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Cass v. Mercer Cty. Sheriff's Office
| 2025-00049PQ | Public Records; R.C. 2743.75(D)(2); a complaint is properly dismissed pursuant to R.C. 2743.75(D)(2) if the public records request to be enforced is facially overbroad. | Sadler | |
1/24/2025
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2/13/2025
| 2025-Ohio-477 |
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Newman v. Greater Columbus Arts Council
| 2024-00619PQ | Public Records; R.C. 149.011(A); R.C. 149.431; While the availability of relief under R.C. 149.431 does not automatically preclude a finding of functional equivalence, its applicability cuts against functional equivalence; A non-profit entity covered by R.C. 149.431 may be required to produce records even if it is not the functional equivalent of a public office; Financial records covered by R.C. 149.431 relate to money or the way money is managed or pertain to monetary receipts and expenditures. | Marti | |
1/23/2025
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2/13/2025
| 2025-Ohio-471 |
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Cass v. Mercer Cty. Sheriff's Office
| 2025-00049PQ | Public Records; R.C. 2743.75(D)(2); a complaint is properly dismissed pursuant to R.C. 2743.75(D)(2) if the public records request to be enforced is facially overbroad. | Marti | |
1/23/2025
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2/13/2025
| 2025-Ohio-478 |
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Hayden v. Ohio Dept. of Rehab. & Corr.
| 2024-00454JD | Motion for summary judgment; Civ.R. 56; false imprisonment. Plaintiff failed to establish the existence of an issue of material fact as to whether Defendant falsely imprisoned Plaintiff. Defendant’s motion for summary judgment was granted. | Sadler | |
1/22/2025
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2/18/2025
| 2025-Ohio-519 |
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Kearns v. Boardman Twp. Police Dept.
| 2024-00776PQ | Public Records; R.C. 149.43(A)(1)(dd); R.C.149.43(A)(17)(p) and (q); R.C. 149.45(A); R.C. 149.45(A) only exempts information about individuals; Neither 149.43(A)(1)(dd) nor R.C. 149.45(A) exempt license plate numbers from the class of public records; Neither 149.43(A)(1)(dd) nor R.C. 149.45(A) exempt insurance information from the class of public records; Neither 149.43(A)(1)(dd) nor R.C. 149.45(A) exempt vehicle registration information from the class of public records; Neither 149.43(A)(1)(dd) nor R.C. 149.45(A) exempt images of individuals from the class of public records; Neither 149.43(A)(1)(dd) nor R.C. 149.45(A) exempt offender’s residential addresses from the class of public records; R.C.149.43(A)(17)(p) and (q) only exempt images of the interior of residences and private businesses from the class of public records. | Marti | |
1/21/2025
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2/13/2025
| 2025-Ohio-475 |
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Wilson v. Montgomery Cty. Dept. of Job & Family Serv.
| 2024-00675PQ | Public Records; R.C. 2151.421; R.C. Chapter 2743; R.C. 2743.75(D)(2); R.C. 5153.17. | Marti | |
1/15/2025
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2/13/2025
| 2025-Ohio-473 |
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Morrison v. Mt. Vernon, Safety Serv. Dir. Office
| 2023-00226PQ | On Requester’s motion for contempt, and after a show-cause hearing, the Court denied Requester’s motion for contempt. However, the Court found by clear and convincing evidence that Mr. Tanner Salyers, in his capacity as Safety Service Director of the City of Mount Vernon, Ohio, and Mr. P. Robert Broeren, Jr., in his capacity as Director of Law, City of Mount Vernon, Ohio, were in indirect civil contempt for failing appear at the show-cause hearing, absent good cause shown. The Court imposed a civil fine with instructions for purging the civil contempt. | Cain | |
1/14/2025
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2/13/2025
| 2025-Ohio-470 |
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Wilson v. Montgomery Cty. Dept. of Job & Family Serv.
| 2024-00675PQ | Public Records; R.C. 2151.421; R.C. Chapter 2743; R.C. 2743.75(D)(2); R.C. 5153.17; A case is properly dismissed pursuant to R.C. 2743.75(D)(2) if asserts claims beyond the court’s capacity to resolve; a party can access records otherwise protected by R.C. 2151.421 and R.C. 5153.17 if he shows “good cause” for granting him access; Good cause exists if access would be in the best interests of the children involved or if access is necessary to prevent a denial of due process; The determination of whether good cause exists is usually made by the trial court presiding over the proceedings where the records would be used; The existence of good cause to override the confidentiality provided by R.C. 2151.421 and R.C. 5153.17 is primarily a domestic relations matter; R.C. Chapter 2743 does not give the Court of Claims jurisdiction over domestic relations matters. | Marti | |
1/14/2025
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2/13/2025
| 2025-Ohio-474 |
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Tentacles of Cuyahoga Cty. v. Cuyahoga Cty. Pros. Office
| 2024-00628PQ | R.C. 149.43(A)(1)(b). The court overruled requesters’ objections and adopted the special master’s report and recommendation because mere discussion of records pertaining to probation and parole proceedings or proceedings related to the imposition of community control sanctions does not amount to disclosure. | Sadler | |
1/8/2025
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2/13/2025
| 2025-Ohio-472 |
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Five Guys Dev., L.L.C. v. Ohio Dept. of Transp.
| 2024-00724JD | Motion to Dismiss; Civ.R. 12(B)(6); subject matter jurisdiction; R.C. 2743.02; R.C. 2743.16(A); declaratory judgment. Plaintiff brought six claims against Defendant, alleging that Defendant engaged in prohibited conduct with relation to a parcel of Plaintiff’s real property. The Court of Claims did not have jurisdiction to hear Plaintiff’s claims brought under R.C. 163, as the statute specifically confers jurisdiction upon the common pleas court or the probate court to adjudicate alleged violations. Plaintiff’s claims for trespass and nuisance were barred by the relevant statute of limitations, as Plaintiff’s complaint conclusively established that Plaintiff had knowledge of Defendant’s alleged unauthorized conduct more than two years prior to Plaintiff bringing its actions in the Court of Claims. While a specific exception exists that permits the Court of Claims to hear taking actions when the claimant is uncompensated, the Court did not have jurisdiction to hear Plaintiff’s taking claim as Plaintiff’s complaint established that the matter of appropriation of the real property was pending in another court. Finally, because the Court did not have jurisdiction to hear Plaintiff’s claims for money damages, it also did not have jurisdiction to hear Plaintiff’s action for declaratory judgment related to those same issues. Defendant’s motion to dismiss was granted. | Cain | |
1/7/2025
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2/18/2025
| 2025-Ohio-520 |