Kolkowski v. Ashtabula Area City School Dist.

Citations

• 2026 Ohio 1721

Syllabus

Special master recommended additional production of records because legal counsel for the public office satisfied the quasi-agency test; records related to the delegated public duty, defense of legal action, were therefore subject to public-records production. Requester was only entitled to production of records that existed on or before the date of the public-records request. Public office appropriately redacted non-records (personal email addresses) and records pursuant to the attorney-client privilege. Public office's delay of two years to produce all records was not reasonable, although requester took no action on requests during that time.