White v. Ross Corr. Inst.

Citations

• 2025 Ohio 2884

Syllabus

Public Records; R.C. 3.20; R.C. 149.43(A)(1)(a) and (3), R.C. 149.43(A)(1)(v); R.C. 149.43(C)(2); Pursuant to R.C. 3.20, a R.C. 149.43(C(2) affirmation is considered to be made under oath; An R.C. 149.43(C(2) affirmation may be made in the body of the R.C. 2743.75 complaint; An internal agency policy, not rising to the level of an administrative rule, provides no basis for denying a R.C. 149.43 records request; Records generated after a patient's death are not medical records within the meaning of 149.43(A)(1)(a) and (3) because they were not generated in the course of treatment.