Martin v. Accel Schools Ohio

Citations

• 2024 Ohio 5965

Syllabus

Public Records; Community Schools; R.C. 149.011(A); R.C. 149.011(G); R.C. 149.43(A)(1); R.C. 2743.03(A)(3)(b); Adm. Code 3301-102-02(I); The functional equivalence doctrine; The quasi-agency doctrine; The governing authority of a R.C. Chapter 3314 community school is analogous to the board of education of a school district; R.C. 2743.03(A)(3)(b) grants the court of claims jurisdiction over public records disputes regardless of whether the respondent is a state entity, a political subdivision, or an employee of one of those entities; R.C. 2743.03(A)(3)(b) grants the court of claims jurisdiction over public records disputes regardless of whether the respondent is a private party; The four factors identified in the functional equivalence test adopted by State ex rel. Oriana House, Inc. v. Montgomery, 2006-Ohio-4854, are a nonexhaustive list; Out of state precedents applying the functional equivalence test are relevant to cases applying it in Ohio; Public education as a fundamental governmental function; Administrative actions taken on behalf of R.C. Chapter 3314 community schools are governmental acts; The extent of government involvement or regulation factor of the functional equivalence test can be established with proof of either a high degree of involvement with government or a high degree of regulation by government; A private entity is likely to be the functional equivalent of a public office if it is closely intertwined with a government body, even if the entity's day-to-day operations are not controlled by government; Mutual dependence between a private entity and a public office supports functional equivalence; A fiduciary relationship between a private entity and a public office supports functional equivalence; An entity that manages all aspects of a R.C. Chapter 3314 community school's operations stands in the shoes of the school; Functional equivalence is supported by large outflows of public money from the public office because the public has an interest i