Parra v. Jackson

Citations

• 206 N.E.3d 862
• 2023 Ohio 216

Syllabus

Law enforcement investigatory privilege subpoena prosecutor file Frankenhauser factors de novo in camera compelling need public's interest. The trial court erred in part when it denied the prosecutor's office a protective order over its files related to open, ongoing cases and investigations. Pursuant to a de novo in camera inspection of the files at issue, we find that the plaintiff-appellee has not demonstrated a compelling need that outweighs the public's interest in keeping the vast majority of the documents within the prosecutor's files confidential. Judgment affirmed in part and reversed in part.