Mohr v. Colerain Twp.

Citations

• 2019 Ohio 474

Syllabus

Public records. On review of a special master's report and recommendation, the court found an error of law was evident on the face of the report and recommendation because the special master applied a clear-and-convincing standard of proof in determining that a respondent failed to prove certain exceptions. Since the special master concluded that the requester's requests were for either non-records, or for records that did not exist, the court adopted the report and recommendation, excepting the special master's application of a clear-and-convincing standard of proof. The court modified the report and recommendation, and adopted, as modified, the report and recommendation.