Dye v. Cleveland

Citations

• 2025 Ohio 2375

Syllabus

Public Records; R.C. 149.43(A); R.C. 149.43(A)(1)(g) and (4); R.C. 2743.75; R.C. 2743.75(E)(3)(c); Attorney-Client Privilege; A court should be hesitant to dispose of potentially meritorious claims based on a lay person's inartful submissions in a case brought pursuant to R.C. 2743.75 because that statute is intended to provide a forum for those that are not schooled in the law; Evidence filed after deadlines set pursuant to R.C. 2743.75(E)(3)(c) should not be considered over the opposing party's objection; A court will only undertake individualized scrutiny of redactions if they are specifically challenged; The work product doctrine is distinct from the attorney-client privilege and fits within a different exemption from the Public Records Act; Communications about public relations concerns are not protected by the attorney-client privilege absent evidence that the public relations communications involved the formulation of legal, rather than public relations, advice; R.C. 149.43 does not require public offices to provide privilege logs.