Geauga Cty. Prosecutor's Office v. Munson Fire Dept.

Citations

• 2023 Ohio 3958

Syllabus

Public Records R.C. 149.011(A) R.C. 149.43(B)(1) Applicability of Public Records Act to private entities Functional equivalence test Fire protection and EMS services are governmental functions A private entity is more likely to be the functional equivalent of a public office if it's public funding is given in bulk rather than on a set fee for set service basis a private entity can be the functional equivalent of a public office if it is closely intertwined with government, even if it maintains control of its day-to-day activities A private entity is more likely to be the functional equivalent of a public office if it owes fiduciary duties to the public a complete delegation of a public function to a private entity supports functional equivalence Quasi-agency doctrine.