| Case Caption | Case No. | Topics and Issues | Author | Citation / County | Decided | Posted | WebCite |
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NW Ohio Innocence Clinic v. Lucas Cty. Prosecutor's Office
| 2025-00973PQ | Special master recommended additional production of records. Public office did not meet its burden to establish that withheld records clearly fell under the Confidential Law Enforcement Investigatory Records ("CLEIR") work product exception (R.C. 149.43(A)(1)(h) and 149.43(A)(2)(b)). Public office correctly withheld grand jury records (Crim.R. 6(E)). | Pierce | |
2/26/2026
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3/19/2026
| 2026-Ohio-918 |
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Thompson v. Tiffin City Schools
| 2025-00892PQ | Special master recommended additional production of records. The public office did not appropriately redact certain records pursuant to student privacy exceptions (R.C. 3319.21 and 20 U.S.C. §1232g (FERPA)). The public office incorrectly withheld records as medical records (R.C. 149.43(A)(1)(a)). The public office did not introduce evidence to justify withholding a record as a security record (R.C. 149.433). The public office incorrectly withheld certain records as non-record (R.C. 149.011(G)). Requester did not carry his burden on all other claims for additional production or unreasonable delay. | Pierce | |
2/24/2026
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3/19/2026
| 2026-Ohio-916 |
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Grant v. Ohio Dept. of Rehab. & Corr.
| 2024-00127JD | Inmate Assault, Negligence, Notice. Plaintiff failed to prove that defendant had notice of an impending assault on him by another inmate. The magistrate further found that plaintiff’s arguments regarding inadequate staffing levels and Covid-era partitions were barred by discretionary immunity. Plaintiff’s argument regarding post-order violations was unsubstantiated, but even if proven it would not have put defendant on notice of the impending assault. The magistrate recommended judgment be entered in favor of defendant. | Peterson | |
2/23/2026
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3/16/2026
| 2026-Ohio-881 |
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Richardson v. Dept. of Rehab. & Corr.
| 2025-00969AD | Inmate; dog bite; damages. Plaintiff, an inmate, was bitten on the hand by a dog that was part of the canine training program at the institution. Defendant admitted liability but disputed the amount of plaintiff’s damages. Judgment for plaintiff. | Shaver | |
2/20/2026
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3/9/2026
| 2026-Ohio-791 |
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Seim v. Perry Twp.
| 2025-00722PQ | Public office ordered to provide access to requested records. Requester introduced evidence to demonstrate that the requested records exist. | Sadler | |
2/19/2026
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3/19/2026
| 2026-Ohio-915 |
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Souare v. Bur. of Motor Vehicles
| 2025-00965PQ | Complaint dismissed because requester’s filings demonstrate the requester does not seek relief that can be granted by the court in a R.C. 2743.45 case. | Sadler | |
2/19/2026
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3/19/2026
| 2026-Ohio-921 |
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McKinley v. Ohio Dept. of Pub. Safety
| 2025-00859AD | Negligence; emergency call; public duty; proximate cause. Plaintiff was driving a semi-trailer while stopped at a traffic light. Defendant’s employee, a state trooper, negligently drove his vehicle into plaintiff’s trailer. The evidence did not support defendant’s argument that the trooper was on an emergency call at the time of the incident. The public duty rule also did not apply in this situation. However, plaintiff failed to prove that the minor traffic incident was the proximate cause of his personal injury and request for damages. Judgment for defendant. | Shaver | |
2/18/2026
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3/9/2026
| 2026-Ohio-792 |
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Souare v. Bur. of Motor Vehicles
| 2025-00965PQ | Special master recommended dismissal where requester’s filings demonstrated that the requester no longer sought public records relief. | Pierce | |
2/18/2026
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3/19/2026
| 2026-Ohio-920 |
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Morris v. Cleveland
| 2025-00959PQ | Special master recommended judgment for the public office. The public office provided redacted records to the requester. Requester did not demonstrate that any further responsive records exist. The public office properly redacted the records pursuant to attorney work product (R.C. 149.43(A)(1)(zz)), attorney-client privilege (R.C. 149.43(A)(1)(v)), and crime victim privacy (R.C. 2930.07 and 149.43(A)(1)(rr)). The public office introduced evidence to explain the response time, which was not unreasonable. | Pierce | |
2/17/2026
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3/19/2026
| 2026-Ohio-922 |
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Edoja v. Ohio State Univ. Wexner Med. Ctr.
| 2022-00837JD | Medical negligence; standard of care. In a trial before the judge, judgment was rendered in favor of defendant on four theories of medical negligence, as the court determined that the medical care provided to the decedent met the applicable standard of care and that plaintiff failed to establish, by a preponderance of the evidence, any of the alleged breaches set forth in the complaint. Judgment for defendant. | Sadler | |
2/12/2026
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3/16/2026
| 2026-Ohio-880 |
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McEachron v. Garfield Hts.
| 2025-00922PQ | Special master recommended dismissal because requester failed to demonstrate that he sought an identifiable public record and his public records requests were too vague and indefinite to be enforceable. | Pierce | |
2/12/2026
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3/19/2026
| 2026-Ohio-923 |
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Souare v. Dept. of Dev. Disabilities
| 2025-00966PQ | Complaint dismissed because public office introduced evidence to demonstrate that requester did not comply with R.C. 149.43(C)(2) requirements. | Pierce | |
2/11/2026
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3/19/2026
| 2026-Ohio-919 |
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Crangle v. Ohio Dept. of Rehab. & Corr.
| 2024-00716JD | Civ.R. 41(B)(2); inmate; unauthorized disclosure of medical information. Plaintiff failed to present evidence showing any right to relief for his claims establishing defendant made an unauthorized, unprivileged disclosure to a third party of his confidential medical information. Magistrate recommended dismissal of action pursuant to Civ.R. 41(B)(2). | Van Schoyck | |
2/10/2026
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3/16/2026
| 2026-Ohio-882 |
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Conforti v. Macedonia Police Dept.
| 2025-00668PQ | The court overruled requester’s objections to the special master’s report and recommendation because requester’s case was mooted by production of the requested public records. Further, the court found that the special master’s recommendation that costs be split between the parties was within the ordinary application of the law. | Sadler | |
2/10/2026
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3/19/2026
| 2026-Ohio-914 |
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Gales v. Dept. of Rehab. & Corr.
| 2025-00893PQ | Neither party filed objections to a special master’s recommendation to deny respondent’s motion to dismiss and to order respondent to produce responsive records. Upon independent review, the court found no error of law or other defect evident on the face of the report and recommendation, and the court adopted the report and recommendation. | Sadler | |
2/2/2026
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3/19/2026
| 2026-Ohio-917 |
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Mash v. Marysville Police Div.
| 2025-00896PQ | On Requester’s objections, the Court overruled the objections to a Report and Recommendation and adopted the Report and Recommendation. The Court ordered Respondent to provide certain records, subject to redaction, to Requester. The Court determined that Requester was entitled to recover from Respondent the amount of the filing fee of twenty-five dollars and any other costs associated with the action that were incurred by Requester, excepting attorney fees. | Sadler | |
1/29/2026
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2/13/2026
| 2026-Ohio-497 |
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Cephas v. Ohio Dept. of Rehab. & Corr.
| 2024-00825JD | Inmate Assault, Rape, Negligence, Damages, Stipulation. Defendant stipulated that its employees breached their duty of care towards plaintiff after eight inmates entered plaintiff’s cell, then assaulted and raped plaintiff for approximately 90 minutes before staff intervention. A trial was held on the issue of damages. The magistrate found that the testimony of plaintiff’s treating physician, who also served as defendant’s medical expert, was credible in that plaintiff’s hip injuries were consistent with normal wear and tear, not an acute injury from the attack. The magistrate further found that plaintiff had proven pain and suffering damages from the attack and recommended an award of $175,000.00 in compensatory damages. | Peterson | |
1/28/2026
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2/3/2026
| 2026-Ohio-326 |
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Seim v. Perry Twp.
| 2025-00722PQ | Respondent unreasonably delayed responses to requester’s public records requests (R.C. 149.43(B)(1)). Requester demonstrated with extrinsic evidence that respondent improperly denied access to responsive public records. | Pierce | |
1/27/2026
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2/13/2026
| 2026-Ohio-492 |
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Newman v. Greater Columbus Arts Council
| 2025-00749PQ | Adopting report and recommendation. A private entity that contracts with a political subdivision is subject to the public records requirements of R.C. 149.431. | Sadler | |
1/21/2026
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2/13/2026
| 2026-Ohio-493 |
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Strahm v. Ohio Dept. of Natural Resources
| 2025-00993PQ | Requester failed to plead or attach a public records request made to one respondent. Dismissal of that respondent recommended for failure to state a claim—requester is not “allegedly aggrieved” by the respondent per R.C. 2743.45(D)(1). | Pierce | |
1/21/2026
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2/13/2026
| 2026-Ohio-499 |
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Anderson v. Dept. of Rehab. & Corr.
| 2025-00852AD | Inmate; property loss; bailment; extortion. Plaintiff, an inmate, claimed that defendant failed to properly secure plaintiff’s property which resulted in it being stolen by other inmates. Plaintiff also alleged that the thief obtained the phone number of plaintiff’s spouse and extorted money from him. Defendant admitted liability for property loss but not for extortion. Plaintiff failed to prove claims of extortion and pain and suffering. Judgment for plaintiff for property loss. | Shaver | |
1/20/2026
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3/9/2026
| 2026-Ohio-793 |
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Dyer v. Great Parks of Hamilton Cty.
| 2025-01029PQ | Complaint dismissed for failure to state a claim. Requester did not attach original public records request as required by R.C. 2743.75(D)(1). The terms of requester’s alleged public records request varied throughout the complaint. Complaint therefore failed to plead facts showing that the requester sought an identifiable public record. | Sadler | |
1/16/2026
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2/13/2026
| 2026-Ohio-500 |
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Dyer v. Great Parks of Hamilton Cty.
| 2025-01029PQ | Requester failed to attach a copy of the original public records request as required by R.C. 2743.75(D)(1) and failed to cure the pleading deficiency. Dismissal recommended per R.C. 2743.45(D)(2) for failure to state a claim. | Pierce | |
1/15/2026
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2/13/2026
| 2026-Ohio-501 |
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Hutton v. Dept. of Rehab. & Corr.
| 2025-00808AD | Inmate; property loss; bailment. Plaintiff, an inmate, claimed that his typewriter was damaged when defendant failed to properly pack it for shipping to an outside repair company. Judgment for plaintiff. | Shaver | |
1/13/2026
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3/9/2026
| 2026-Ohio-794 |
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Gales v. Ohio Dept. of Rehab. & Corr.
| 2025-00893PQ | public record; R.C. 149.43; court of claims; R.C. 2743.75. Requester sought records regarding the authority of respondent to incarcerate her husband in a state correctional institution. Respondent did not substantively respond to the records request. Respondent moved to dismiss the complaint arguing that requester did not follow the procedural requirements of R.C. 149.43 when initiating her claim and that requester failed to state a claim upon which relief can be granted under R.C. 2743.75. The special master found, however, that requester satisfied the procedural requirements and raised a valid public records complaint, and the special master recommended that respondent be ordered to produce all responsive records. | Van Schoyck | |
1/12/2026
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2/13/2026
| 2026-Ohio-496 |
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Harris v. Ohio Dept. of Rehab. & Corr.
| 2025-00618AD | Inmate; punitive damages; negligent supervision. Plaintiff, an inmate, claimed that he was refused a meal at the institution because he did not have his identification card. Evidence showed that plaintiff located his identification card shortly after being denied a meal. Plaintiff failed to prove any claim against defendant. Punitive damages are not recoverable in the court of claims. Judgment for defendant. | Shaver | |
1/9/2026
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3/9/2026
| 2026-Ohio-790 |
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Mash v. Marysville Police Div.
| 2025-00896PQ | On in camera review, police department correctly applied the confidential law enforcement investigatory record ("CLEIR") uncharged suspect exception (R.C. 149.43(A)(1)(h) and R.C. 149.43(A)(2)(a)) to redact records related to the investigation of a missing person. Police department incorrectly withheld a record with incident report information under the CLEIR work product exception. | Pierce | |
1/8/2026
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2/13/2026
| 2026-Ohio-498 |
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Cincinnati Enquirer v. Butler Cty. Sheriff's Office
| 2024-00906PQ | On remand from the Twelfth District Court of Appeals, the Court entered judgment in favor of the respondent because the appellate court found that a log of inmate phone calls did not document the organization, functions, policies, decisions, procedures, operations, or other activities of the sheriff's office. | Sadler | |
1/2/2026
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2/13/2026
| 2026-Ohio-490 |
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Conforti v. Macedonia Police Dept.
| 2025-00668PQ | Requester is not entitled to public records relief. Requester did not demonstrate that additional responsive records exist or were withheld from release. On in camera review, police department correctly applied the confidential law enforcement investigatory record ("CLEIR") uncharged suspect exception (R.C. 149.43(A)(1)(h) and R.C. 149.43(A)(2)(a)) to redact video and written records. | Pierce | |
1/2/2026
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2/13/2026
| 2026-Ohio-491 |