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Case CaptionCase No.Topics and IssuesAuthorCitation / CountyDecidedPostedWebCite
Racano v. Ohio Dept. of Transp. 2025-00478ADOhio Department of Transportation; pothole; rental car; Uber ride; collision deductible. Judgment for plaintiff.Shaver  8/27/2025 9/9/2025 2025-Ohio-3236
Cook v. Ohio Dept. of Rehab. & Corr. 2025-00145ADInmate; property loss; bailment; negligence. Judgment for defendant.Shaver  8/13/2025 9/9/2025 2025-Ohio-3228
Ealom v. Ohio Dept. of Rehab. & Corr. 2024-00024JDNegligence; Excessive Force; Ohio Administrative Code. Plaintiff, an inmate, alleged that Ohio Department of Rehabilitation and Correction ("ODRC") correctional officers used excessive force by deploying Oleoresin Capsicum spray during a fight and then failed to properly decontaminate him. The negligence claim proceeded to trial, where the magistrate found that Defendant did not breach its duty of care. Because Plaintiff ignored oral commands, remained unrestrained, and posed a continued threat, the use of force was deemed reasonable under Ohio Adm.Code 5120-9-01. The magistrate also determined that Defendant provided prompt and adequate decontamination and medical care, including immediate removal to fresh air, nursing evaluations, and ongoing treatment for eye irritation. Accordingly, the magistrate recommended judgment in favor of Defendant.Morris  8/8/2025 9/4/2025 2025-Ohio-3141
Deitz v. Shelby Cty. Pros. Office 2025-00339PQPublic Records; R.C. 149.43(B)(1); R.C. 149.433; R.C. 2743.75; The courts uphold the application of R.C. 149.433’s security record provisions when the danger resulting from the release of the record is obvious, or there is robust evidence of “direct” or “verified” threats; The Supreme Court has relied on affidavits from officials with security expertise to find threats supporting the application of R.C. 149.433’s security record provisions when the underlying threat is not obvious; The mere fact that a person vigorously asserted his rights in a dispute with the government did not, by itself, make him an obvious threat supporting the application of R.C. 149.433’s security record provision; A public office fulfills its duty to produce public records when it makes the records available to a requester, even if the requester delays accessing the records. R.C. 2743.75 only gives the court of claims jurisdiction to grant relief for specific violations of R.C. 149.43, the statute does not authorize broader relief.Marti  7/31/2025 8/14/2025 2025-Ohio-2881
In re J.S. 2025-00179VIVictims of crime. No objections filed. Magistrate’s decision adopted. Applicant’s claim remanded to the Attorney General for economic loss calculations.Sadler  7/31/2025 9/9/2025 2025-Ohio-3230
Lyrenmann v. Milford Exempted Village Schools 2025-00570PQPublic Records; R.C. 149.011(G); R.C. 149.43(B)(1); R.C. 3319.321; The definition of “personally identifiable information” set forth in 34 C.F.R. § 99.3 is relevant to defining the term for purposes of R.C. 3319.321; Complete withholding of a record containing both public record information and information exempted from the Public Records Act withholding is only permissible if the exempted material is necessarily and inextricably intertwined with the rest of the record; The scope of exempt material must be so pervasive that redaction would thoroughly eviscerate the record as a whole; Complete withholding is not allowed if the exempt material is discrete and severable from the balance of the record; The public office has the burden of proving such intertwining, and any doubts are resolved against complete withholding; The extent of any redaction must be carefully restricted; A public office may properly redact information within an otherwise public record when that information does not fit within the definition of “record” provided by R.C. 149.011(G); A private person’s contact information is not a R.C. 149.011(G) record when the office does not use it to contact the person the information identifies or to verify facts relevant to a matter it is considering.Marti  7/29/2025 8/14/2025 2025-Ohio-2885
Porter v. Ohio Dept. of Rehab. & Corr. 2025-00155ADInmate; property loss; bailment; negligence; damages. Judgment for plaintiff.Shaver  7/29/2025 9/9/2025 2025-Ohio-3229
Ackley v. Washington Court House Police Dept. 2025-00351PQPublic Records; R.C. 149.43(A)(1)(v); Adm. Code 4501:2-10-03(C)(1); Adm. Code 4501:2-10-03(C)(1) is a law prohibiting the release of LEADS materials.Marti  7/23/2025 8/14/2025 2025-Ohio-2882
White v. Ross Corr. Inst. 2025-00474PQPublic 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.Marti  7/22/2025 8/14/2025 2025-Ohio-2884
In re Darling 2025-00213VIVictims of crime. No objections filed. Magistrate’s decision adopted. Applicant’s claim denied.Sadler  7/17/2025 9/9/2025 2025-Ohio-3232
In re Darling 2025-00214VIVictims of crime. No objections filed. Magistrate’s decision adopted. Applicant’s claim denied.Sadler  7/17/2025 9/9/2025 2025-Ohio-3239
In re J.S. 2025-00179VIVictims of crime; civil protection order; attorney fees; statute of limitations; R.C. 2743.60(A)(2)(a); R.C. 2743.60(A)(2)(b). Claim for attorney fees incurred to obtain civil protection order (“CPO”) to separate child victim from offender was filed timely pursuant to statute of limitations for minor claimants in R.C. 2743.60(A)(2)(b). Magistrate recommended that Attorney General’s final decision denying applicant’s claim be reversed and the claim be remanded to the Attorney General for economic loss calculations.Shaver  7/15/2025 9/9/2025 2025-Ohio-3231
Hanson v. Etna Twp. 2025-00243PQPublic Records; R.C. 2743/75(D)(1); Civ. R. 15(B); Although a court considering a public records case will not ordinarily consider unpled claims, that rule is not absolute; Factors guiding the discretion to consider an unpled claim litigated by the consent of the parties.Marti  7/14/2025 8/14/2025 2025-Ohio-2880
In re McCoy 2023-00640VIVictims of crime. Objections overruled. Magistrate’s decision adopted. Applicant’s claim granted.Sadler  7/10/2025 9/9/2025 2025-Ohio-3205
In re Powell 2024-00165VIVictims of crime. No objections filed. Magistrate’s decision adopted. Applicant’s claim remanded to the Attorney General for economic loss calculations.Sadler  7/10/2025 9/9/2025 2025-Ohio-3207
Trader v. Ontario Local School Dist. 2025-00123PQPublic Records.Sadler  7/9/2025 8/14/2025 2025-Ohio-2879
Kidd v. Wilmington 2025-00620PQ, 2025-00621PQ, 2025-00622PQ, 2025-00623PQ, 2025-00624PQ, 2025-00625PQ, 2025-00626PQ, 2025-00627PQ, 2025-00628PQPublic Records; R.C. 2743.75(D)(2); The duplicative nature of a case supports a R.C. 2743.75(D)(2) dismissal.Sadler  7/9/2025 8/14/2025 2025-Ohio-2886
Kidd v. Wilmington 2025-00620PQ, 2025-00621PQ, 2025-00622PQ, 2025-00623PQ, 2025-00624PQ, 2025-00625PQ, 2025-00626PQ, 2025-00627PQ, 2025-00628PQPublic Records; R.C. 2743.75(D)(2); The duplicative nature of a case supports a R.C. 2743.75(D)(2) dismissal.Marti  7/8/2025 8/14/2025 2025-Ohio-2887
Owens v. Ohio Dept. of Rehab. & Corr. 2025-00011ADInmate; property loss; bailment; contraband; JPay tablets; negligence; discretionary immunity. Judgment for plaintiff.Shaver  7/8/2025 9/9/2025 2025-Ohio-3225
Weaver v. Ohio Dept. of Pub. Safety 2023-00573JDMotion for summary judgment; Civ.R. 56; employment discrimination; disability; R.C. 4112.02; wrongful discharge; public policy; failure to accommodate. Plaintiff failed to establish the existence of an issue of material fact as to Plaintiff’s claims against Defendant for wrongful termination in violation of public policy, disability discrimination, and failure to accommodate Plaintiff’s disability. Defendant’s motion for summary judgment was granted.Sadler  7/7/2025 8/18/2025 2025-Ohio-2916
Johnson v. Ohio Dept. of Rehab. & Corr. 2024-00618JDCiv.R. 56; motion for summary judgment; assault; excessive use of force. Defendant was entitled to summary judgment on an inmate plaintiff’s claim for assault and excessive use of force as defendant did not violate the duty of care owed to plaintiff and the corrections officers were justified and privileged to use reasonable force against plaintiff under the circumstances, which did not amount to excessive use of force. Judgment for defendant.Sadler  7/7/2025 8/18/2025 2025-Ohio-2919
In re Darling 2025-00213VIVictims of crime; criminally injurious conduct; R.C. 2743.51(C)(1); R.C. 2743.51(L); R.C. 2743.60(B)(1). Applicant failed to prove that she was a victim of criminally injurious conduct when police report listed her as the offender. Magistrate recommended that Attorney General’s final decision denying applicant’s claim be affirmed.Shaver  7/3/2025 9/9/2025 2025-Ohio-3233
In re Darling 2025-00214VIVictims of crime; criminally injurious conduct; R.C. 2743.51(C)(1); R.C. 2743.51(L); R.C. 2743.60(B)(1). Applicant failed to prove that she was a victim of criminally injurious conduct when police report listed her as the offender. Magistrate recommended that Attorney General’s final decision denying applicant’s claim be affirmed.Shaver  7/3/2025 9/9/2025 2025-Ohio-3235
O'Brien v. Ohio Bur. of Workers' Comp. 2023-00659JDMotion for Summary Judgment, Employment, Disability Discrimination, Sex Discrimination, Retaliation, Failure to Accommodate. No genuine issues as to any material fact existed regarding plaintiff’s claims for disability discrimination, sex discrimination, retaliation, or failure to accommodate. Defendant presented legitimate, non-discriminatory reasons for placing plaintiff on an action plan despite Plaintiff’s conditions of anxiety and depression. Plaintiff failed to establish a prima facie case of sex discrimination because the statements made were not discriminatory and did not adversely affect plaintiff, and plaintiff could point to no comparable employees who were treated more favorably. Plaintiff’s retaliation claim failed because plaintiff was not engaged in a protected activity when he was disciplined. Plaintiff’s failure to accommodate claim failed because plaintiff’s proposed accommodation was not reasonable. Plaintiff failed to establish a prima facie case by presenting facts which demonstrated that defendant’s reasoning was pretextual. Accordingly, Defendant’s motion for summary judgment was granted.Cain  7/2/2025 8/18/2025 2025-Ohio-2918
Welch v. Ohio Dept. of Rehab. & Corr. 2023-00655JDCiv.R. 56; motion for summary judgment; negligence; open and obvious doctrine. Defendant was entitled to summary judgment on an inmate plaintiff’s claim for negligence related to a fall sustained after slipping on water because the court found that there was no genuine issue as to any material fact regarding whether defendant breached a duty owed to plaintiff or whether the puddling water was an open and obvious danger at the time of the fall, and therefore, defendant was entitled to judgment as a matter of law. Judgment for defendant.Sadler  6/25/2025 7/17/2025 2025-Ohio-2514
In re Powell 2024-00165VIVictims of crime; criminally injurious conduct; R.C. 2743.51(C)(1); R.C. 2743.60(A); law enforcement reporting requirement. Applicant satisfied the reporting requirement when he orally reported an assault to hospital staff. Applicant proved by a preponderance of the evidence that he was a victim of criminally injurious conduct. Magistrate recommended that Attorney General’s final decision denying applicant’s claim be reversed and that the claim be remanded to the Attorney General’s office for economic loss calculations.Shaver  6/25/2025 9/9/2025 2025-Ohio-3208
Marquette v. Ohio Univ. 2024-00676ADStudent; breach of contract; syllabus; failing grade; grade appeal process; arbitrary and capricious; faculty handbook; deference to academic decisions of colleges; unambiguous; professional judgment. Judgment for defendant.Shaver  6/25/2025 9/9/2025 2025-Ohio-3218
Bowen v. Ohio Univ. 2024-00880ADStudent; dorm room; safety rail; top bunk bed; concussion; negligence; damages. Judgment for plaintiff.Shaver  6/25/2025 9/9/2025 2025-Ohio-3224
Gibson v. Ohio Dept. of Rehab. & Corr. 2024-00862ADInmate; property loss; bailment; possession; negligence. Judgment for defendant.Shaver  6/25/2025 9/9/2025 2025-Ohio-3238
Kearns v. Fairfield Police Dept. 2025-00017PQPublic Records.Sadler  6/17/2025 7/3/2025 2025-Ohio-2373
Trader v. Ontario Local School Dist. 2025-00123PQPublic Records; R.C. 2743.75(A); R.C. 2743.75(D; ); R.C. 3319.321;R.C. 2743.75(A) grants the court of claims jurisdiction to resolve “disputes alleging a denial of access to public records in violation of division (B) of section 149.43 of the Revised Code,” but does not otherwise give it jurisdiction over political subdivisions; R.C. 2743.75(A) does not give the court of claim jurisdiction over claims seeking affirmative relief under the Family Educational Rights and Privacy Act, but does give the court jurisdiction to determine whether that act provides a basis to redact or withhold a record pursuant to R.C. 149.43(A)(1)(v); R.C. 2743.75(A) does not give the court of claims jurisdiction over retaliation claims; Images of students are personally identifiable information for purposes of R.C. 3319.321; A requester cannot obtain relief on a record request attached to a R.C. 2743.75 complaint when that request is not among the requests specifically identified as a basis for relief in the body of the complaint.Marti  6/16/2025 7/3/2025 2025-Ohio-2374
Blevins v. Ohio Dept. of Rehab. & Corr. 2024-00089JDMagistrate’s Decision, Negligence, res ipsa loquitor, physical injury, property loss. Plaintiff proved his claims by a preponderance of evidence for negligence regarding loss of personal property and physical injury. The magistrate found that a bailment relationship was created when plaintiff was allowed to store personal property in a room only defendant had access to and it was subsequently lost. Additionally, the magistrate found that plaintiff met his burden via res ipsa loquitor in establishing a shiny object hit plaintiff causing physical injury. Judgment was recommended in favor of plaintiff.Morris  6/16/2025 7/17/2025 2025-Ohio-2515
George v. Miami Univ. 2021-00187JDComparative Negligence. After a trial, the Court of Claims adopted the magistrate’s decision, which found that Defendant was liable to Plaintiff for injuries she sustained at Defendant’s ice hockey rink when she fell onto the ice through an open door and was struck by a Zamboni. The Court allocated 70% of fault to Defendant, concluding that both the open door and consequential risk of being struck by a Zamboni were not “open and obvious” hazards. On appeal, the Tenth District Court of Appeals found that the Court of Claims erred in concluding that the open door was not an “open and obvious hazard.” The court of appeals remanded the matter, directing the Court of Claims to determine whether this error had any impact on its comparative negligence calculation. On remand, the Court of Claims held that the “open and obvious” nature of the open door did not affect its comparative negligence calculation. This is because the evidence overwhelmingly established that it was negligent operation of the Zamboni, not Plaintiff’s original fall, that caused her injuries. The Court of Claims upheld its initial allocation of negligence and again rendered judgment in favor of Plaintiff.Cain  6/11/2025 7/17/2025 2025-Ohio-2512
Tunberg v. Ohio Dept. of Transp. 2023-00215JDOhio Department of Transportation ("ODOT"); construction zone; Ohio Manual of Uniform Traffic Control Devices ("OMUTCD"); negligence; wrongful death; survivorship; contributory negligence. The Court found that ODOT breached its duty when it failed to use advance guidance signs for a permanent drop lane exit, failed to properly maintain road lines, and improperly used temporary traffic control devices which did not conform to mandatory provisions of the OMUTCD. This breach caused decedent’s death; however, the Court determined that decedent’s negligence contributed to his death 40 percent. Therefore, judgment was rendered in favor of plaintiff in the amount of $504,000.Cain  6/11/2025 7/17/2025 2025-Ohio-2513
Dye v. Cleveland 2025-00216PQPublic Records; R.C. 149.43(A); R.C. 149.43(A)(1)(g) and (4); R.C. 2743.75; R.C. 2743.75(E)(3)(c); Attorney-Client Privilege; A court should be hesitant to dispose of potentially meritorious claims based on a lay person’s inartful submissions in a case brought pursuant to R.C. 2743.75 because that statute is intended to provide a forum for those that are not schooled in the law; Evidence filed after deadlines set pursuant to R.C. 2743.75(E)(3)(c) should not be considered over the opposing party’s objection; A court will only undertake individualized scrutiny of redactions if they are specifically challenged; The work product doctrine is distinct from the attorney-client privilege and fits within a different exemption from the Public Records Act; Communications about public relations concerns are not protected by the attorney-client privilege absent evidence that the public relations communications involved the formulation of legal, rather than public relations, advice; R.C. 149.43 does not require public offices to provide privilege logs.Marti  6/3/2025 7/3/2025 2025-Ohio-2375
Ramsey v. Cent. State Univ. Bd. of Trustees 2023-00277JDCiv. R. 56; Motions for Summary Judgment; R.C. 4112; sex-based discrimination. Plaintiff, a woman, was demoted from her position at Central State University. Shortly thereafter, she left the University and her role was reassigned to another woman. Plaintiff sued Defendant under R.C. 4112, alleging sex discrimination. Plaintiff presented circumstantial, rather than direct, evidence to support her claim. With said evidence construed in favor of Plaintiff, Plaintiff’s sex discrimination claims could not be maintained. First, while Plaintiff suffered an adverse employment action, she failed to introduce necessary evidence to substantiate her contention that she was treated differently from her male coworkers. Second, Plaintiff’s assertion that she was subject to a hostile work environment was supported by evidence that was either too vague to justify an inference of discrimination or that was unrelated to her sex entirely. As such, Plaintiff failed to establish any indicia of discriminatory animus on behalf of Defendant. Finally, even if Plaintiff had established a prima facie case of sexual discrimination, Plaintiff failed to set forth any evidence that Defendant’s demotion of Plaintiff was pretext for unlawful discrimination based upon sex. Accordingly, Defendant’s motion for summary judgment was granted.Sadler  5/30/2025 6/20/2025 2025-Ohio-2171
Bates v. Ohio Dept. of Rehab. & Corr. 2024-00772JDCiv.R. 56; motion for summary judgment; negligence; inmate; assault; notice. Defendant was entitled to summary judgment on plaintiff’s claim for negligence related to an assault by another inmate while plaintiff was in the custody and control of defendant because defendant did not have actual or constructive notice of any impending inmate assault on plaintiff prior to plaintiff’s assault. Judgment for defendant.Sadler  5/30/2025 6/20/2025 2025-Ohio-2175
Zirkle v. N.E. Ohio Med. Univ. 2023-00433JDMagistrate’s Decision, Ohio Products Liability, R.C. 2307.71, Negligence. Plaintiff failed to prove that the cadaver supplied by defendant contained excess embalming chemicals making it unsafe and unfit for use. Additionally, the Magistrate found that as testified to, the pooling of embalming fluids in the abdominal cavity was an open and obvious danger given the obvious risk of embalming fluids. Judgment was recommended in favor of defendant.Van Schoyck  5/28/2025 6/20/2025 2025-Ohio-2173
Wysong v. Dayton City Hall 2025-00002PQOn objections, the Court overruled Requester’s partial objection to a Special Master’s Report and Recommendation, concluding that the Special Master properly determined that Requester's request for the number of vehicles impounded due to unpaid citations constituted a request for information (which was not an enforceable public-records request) and that Respondent was not required to take any further action on this request.Sadler  5/23/2025 6/5/2025 2025-Ohio-2002
In re McCoy 2023-00640VIVictims of crime; R.C. 2743.51(I); dependent’s economic loss; dependency in fact. Award of dependent’s economic loss was limited to evidence of what deceased parent provided to dependent children, not the child support arrearage he owed. Applicant failed to prove that deceased parent made additional contributions of economic value to his children other than sporadic child support payments. Magistrate recommended that Attorney General’s final decision granting applicant’s claim be affirmed.Shaver  5/20/2025 9/9/2025 2025-Ohio-3206
Lane v. Portage Cty. Sheriffs 2025-00157PQ & 2025-00276PQR.C. 2743.75(D)(1); Civ. R. 15(B).Sadler  5/15/2025 7/8/2025 2025-Ohio-2413
Fields-Arnold v. Cent. State Univ. Bd. of Trustees 2023-00279JDMotion for summary judgment; Civ.R. 56; Local Court of Claims Rules ("L.C.C.R.") 4; employment discrimination; race; age; sex; Family and Medical Leave Act ("FMLA"); university. Plaintiff failed to establish the existence of an issue of material fact as to Plaintiff’s employment discrimination and FMLA retaliation claims. Defendant’s motion for summary judgment was granted.Sadler  5/14/2025 6/20/2025 2025-Ohio-2172
Bentley v. Ohio Dept. of Pub. Safety 2024-00062JDCiv.R. 56; motion for summary judgment; negligence; loss of consortium; emergency call; public duty doctrine. Defendant was entitled to summary judgment on plaintiffs’ claim for negligence related to a motor vehicle accident with an Ohio State Highway Patrol vehicle because the court found that the trooper involved in the collision was responding to an emergency call at the time, and therefore, defendant was entitled to immunity as a matter of law as plaintiffs failed to assert that defendant’s conduct was willful or wanton. As plaintiffs’ claim for negligence failed, since a claim for loss of consortium is a derivative claim, it also failed as a matter of law. Judgment for defendant.Sadler  5/14/2025 6/20/2025 2025-Ohio-2174
Kearns v. Fairfield Police Dept. 2025-00017PQPublic Records; R.C. 149.43(A)(1)(jj); 149.43(A)(17); a public office improperly redacts video recorded by a body worn camera if the quality of the recording prevents the viewer from being able to perceive allegedly exempted information.Marti  5/7/2025 6/5/2025 2025-Ohio-2003
Blakeslee v. Ohio Dept. of Transp. 2025-00100ADOhio Department of Transportation; pothole; towing expenses. Judgment for plaintiff.Shaver  5/2/2025 9/9/2025 2025-Ohio-3227
Wysong v. Dayton City Hall 2025-00002PQPublic Records; R.C. 149.011(G); Quasi-agency doctrine; The exercise of a police power is a governmental function that can support the application of the quasi-agency doctrine.Marti  4/30/2025 5/8/2025 2025-Ohio-1651
Siegel v. Univ. of Cincinnati College of Med. 2009-09531JDJudgment Entry, Plaintiffs’ Objections, Civ.R. 53(D)(3)(b). The Magistrate issued a decision recommending judgment for defendant finding that plaintiffs’ claims were barred by the statute of limitations and that plaintiffs had failed to prove their claims for fraud and spoliation of evidence. Plaintiffs filed objections. The Judge determined that the Magistrate properly determined the factual issues and appropriately applied the law. The Judge overruled the objections and adopted the Magistrate’s decision with modification to reflect the Court’s analysis. Judgment for defendant.Sadler  4/25/2025 5/22/2025 2025-Ohio-1823
Lane v. Portage Cty. Sheriff's Office 2025-00157PQ & 2025-00276PQR.C. 2743.75(D)(1); Civ. R. 15(B); A public office impliedly consents to the litigation of a claim not pled in the body of a R.C. 2743.75(D)(1) complaint when the attachments to the complaint unambiguously raise the claim and the public office addresses the claim on the merits in its response to the complaint.Marti  4/23/2025 7/8/2025 2025-Ohio-2414
Miller v. E. Holmes School Dist. 2025-00088PQPublic Records; 2743.75(D); A requester invoking R.C. 2743.75 must identify the claims he is asserting in the body of his complaint when the attachments reflect multiple public records requests, some of which have apparently been resolved, and some of which may not have been resolved.Sadler  4/22/2025 5/8/2025 2025-Ohio-1652
Smith v. Ohio Dept. of Rehab. & Corr. 2025-00035ADInmate; property loss; authorized source; negligence; civil conspiracy; contraband. Judgment for defendant.Shaver  4/22/2025 9/9/2025 2025-Ohio-3226
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