Deitz v. Shelby Cty. Pros. Office

Citations

• 2025 Ohio 2881

Syllabus

Public Records; R.C. 149.43(B)(1); R.C. 149.433; R.C. 2743.75; The courts uphold the application of R.C. 149.433's security record provisions when the danger resulting from the release of the record is obvious, or there is robust evidence of \direct\ or \verified\ threats; The Supreme Court has relied on affidavits from officials with security expertise to find threats supporting the application of R.C. 149.433's security record provisions when the underlying threat is not obvious; The mere fact that a person vigorously asserted his rights in a dispute with the government did not, by itself, make him an obvious threat supporting the application of R.C. 149.433's security record provision; A public office fulfills its duty to produce public records when it makes the records available to a requester, even if the requester delays accessing the records. R.C. 2743.75 only gives the court of claims jurisdiction to grant relief for specific violations of R.C. 149.43, the statute does not authorize broader relief.