Lyrenmann v. Milford Exempted Village Schools

Citations

• 2025 Ohio 2885

Syllabus

Public Records; R.C. 149.011(G); R.C. 149.43(B)(1); R.C. 3319.321; The definition of \personally identifiable information\ set forth in 34 C.F.R. § 99.3 is relevant to defining the term for purposes of R.C. 3319.321; Complete withholding of a record containing both public record information and information exempted from the Public Records Act withholding is only permissible if the exempted material is necessarily and inextricably intertwined with the rest of the record; The scope of exempt material must be so pervasive that redaction would thoroughly eviscerate the record as a whole; Complete withholding is not allowed if the exempt material is discrete and severable from the balance of the record; The public office has the burden of proving such intertwining, and any doubts are resolved against complete withholding; The extent of any redaction must be carefully restricted; A public office may properly redact information within an otherwise public record when that information does not fit within the definition of \record\ provided by R.C. 149.011(G); A private person's contact information is not a R.C. 149.011(G) record when the office does not use it to contact the person the information identifies or to verify facts relevant to a matter it is considering.