Seiverth v. Perrysburg

Citations

• 2023 Ohio 2319

Syllabus

Public Records Attorney-Client Privilege R.C. 149.43(A) R.C. 3701.17(B) Public Office's burden of proving the applicability of an exemption from the general duty to provide access to records Burden of proving the elements of attorney-client privilege Failure to explain bases for redactions based on attorney-client privilege precludes the privilege Disclosure of privileged records to adverse party waives attorney-client privilege. R.C. 3701.17(B) does not justify withholding of records absent proof that the information in the records was reported to or obtained by one of the health-related entities listed in the statute.