Wengerd v. E. Wayne Fire Dist.

Citations

• 2017 Ohio 8951

Syllabus

Core Terms: public record court of claims R.C. 2743.75 R.C. 149.43 R.C. 1333.61 kept person responsible trade secret copyright grant application attorney-client moot. Overview: Requester sought copies of federal grant application forms filed by respondent fire district. Respondent claimed that the contents of the applications were not \records\ of the fire district, or alternatively were trade secret and copyright interests held by the fire district and a privately contracted grant writer. The special master found that the applications were public records documenting the official activities of the fire district, and that the contents did not reveal any secret trade methodology. As technical writing to answer questions in an application form, the contents involved negligible creativity as a claimed \literary work.\ Requester's purpose qualified as \fair use\ in any case. The special master recommended a finding that the contents of the grant applications did not fall under either the Ohio uniform trade secrets act, or federal copyright law. The special master found the that respondent had properly redacted the narrative portions of requested itemized attorney billing statements.