Zamlen-Spotts v. Cleveland State Univ.

Citations

• 2021 Ohio 2704

Syllabus

public record R.C. 149.43 court of claims R.C. 2743.75 intellectual property R.C. 149.43(A)(5) privacy. Requester sought copies of returned survey forms collected by respondent in the course of public opinion research regarding township policy planning. Respondent asserted the records were excepted from release as \intellectual property records\ of a state institution of higher learning as defined in R.C. 149.43(A)(5) and were also exempt from disclosure due to the \reasonable expectation of privacy\ of survey participants. The special master found that respondent failed to demonstrate any existing constitutional right of privacy for persons responding to public opinion surveys but that the records did meet the definition in R.C. 149.43(A)(5) and were thus exempt from mandatory public records disclosure.