Buduson v. Cleveland

Citations

• 2019 Ohio 963

Syllabus

Core Terms: public record court of claims R.C. 2743.75 R.C. 149.43 ambiguous overly broad R.C. 187.04(C) JobsOhio trade secret. Overview: Requester sought all documentation related to respondent's bid to host the second headquarters of Amazon.com, Inc. (HQ2). Respondent asserted that the request was ambiguous and overly broad, and that that portions of the records were excepted from public records release under R.C. 187.04(C) and as trade secret information. The special master found that the request reasonably identified the formal bid document but was otherwise ambiguous and overly broad. The special master further found that R.C. 187.04(C) exempted only \records created by JobsOhio\ from the Public Records Act, not information obtained from JobsOhio and then dispersed into other records of a public office. The special master found that one six-page document could be withheld as a record created by JobsOhio. The special master found that respondent failed to show that any withheld information constituted a trade secret of Cleveland. The special master recommended that the court order respondent to provide requester with the bid document, other than the exempt six pages.