Tobias v. Ohio Secy. of State's Office

Citations

• 2023 Ohio 4440

Syllabus

Public Records R.C. 149.43(A)(1)(h) & (2)(a) A matter pertains to law enforcement for purposes of R.C. 149.43(A)(2) if it addresses violations of law, even if those violations were initially suggested by routine practices An office invoking the uncharged suspect CLEIR exception must prove that the suspect remains uncharged A charge is an objectively verifiable occurrence: an arrest, a citation, or some other official action asserting a specifically identified violation of law An office invoking an exemption triggered by record-specific facts does not meet its burden by asserting the exemption as to a group of records generally. The office must instead establish the triggering facts on a record-by-record basis.