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| Case Caption | Case No. | Topics and Issues | Author | Citation / County | Decided | Posted | WebCite |
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McCurley v. W. Chester Twp.
| 2025-00470PQ | Public Records. | Sadler | |
9/30/2025
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10/20/2025
| 2025-Ohio-4788 |
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Griffin v. Ohio Dept. of Rehab. & Corr.
| 2024-00577JD | Civ.R. 41(B)(2); medical expert testimony; medical negligence; negligence. Plaintiff failed to establish proximate cause of his injuries with expert testimony as required, as the injuries sustained were not sufficiently observable, understandable, or comprehensible to a layperson and uniquely within the scope of expert scientific inquiry. Magistrate recommended that this action be dismissed pursuant to Civ.R. 41(B)(2). | Morris | |
9/26/2025
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10/16/2025
| 2025-Ohio-4749 |
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Joy v. New Lebanon
| 2025-00616PQ | On objections, the Court overruled Requester’s objections to a Special Master’s Report and Recommendation, concluding that Requester had not established an entitlement to unredacted copies of certain legal invoices by clear and convincing evidence. The Court adopted the Report and Recommendation and denied Respondent’s Civ.R. 12(B)(6) motion. | Cain | |
9/24/2025
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10/20/2025
| 2025-Ohio-4792 |
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Castellon v. Ohio Dept. of Rehab. & Corr.
| 2024-00507JD | Defamation; Qualified Privilege; Negligence; Public Records; Breach of Contract/Promissory Estoppel. Plaintiff, a former inmate, brought multiple claims against Ohio Department of Rehabilitation and Correction ("ODRC") after he was charged with institutional rule violations based on written communications he sent to prison officials criticizing the cancellation of Hispanic Heritage Month events. The Chief of Security authored a conduct report characterizing Plaintiff’s statements and subsequent discussion as “implied” or “vague” threats, resulting in Plaintiff’s placement in restricted housing and later transfer. Plaintiff alleged that the statements in the conduct report were defamatory and that an Institutional Inspector wrongfully withheld records necessary to pursue his claims. On cross-motions for summary judgment, the Court found that the statements reflected opinion—not verifiable fact—and were protected by qualified privilege, as they were made in good faith within the scope of official duties and limited to appropriate prison staff. Plaintiff offered no evidence of actual malice sufficient to overcome the privilege. The Court also dismissed the abuse of process claim (which Plaintiff had withdrawn), the intentional tort claim (as duplicative of the defamation theory and jurisdictionally barred insofar as it challenged housing and transfer decisions), the negligence claim (because alleged violations of public records law must be pursued through mandamus or an R.C. 2743.75 action, not negligence), and the breach of contract/promissory estoppel claim (because no contract or enforceable promise existed, and statutory duties under the Public Records Act do not create contractual rights). The Court therefore granted Defendant’s Motion for Summary Judgment, denied Plaintiff’s Motion for Summary Judgment, and entered judgment in favor of Defendant. | Sadler | |
9/19/2025
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10/16/2025
| 2025-Ohio-4747 |
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Norris v. Ohio Dept. of Rehab. & Corr.
| 2025-00175JD | Motion for summary judgment; Civ.R. 56; false imprisonment; immunity; res judicata. Plaintiff failed to establish the existence of an issue of material fact as to Plaintiff’s claim against Defendant for false imprisonment. Defendant’s motion for summary judgment was granted. | Sadler | |
9/19/2025
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10/16/2025
| 2025-Ohio-4750 |
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Reese v. Ohio Dept. of Rehab. & Corr.
| 2024-00557JD & 2024-00558JD | Magistrate’s Decision, Civ.R. 41(B)(2), Property Loss, Negligence, Medical Expert Testimony. Plaintiff testified that after failing to take a prescribed medication due to defendant’s negligence, plaintiff required surgery to replace/repair his aorta. The magistrate found that in the absence of expert testimony, plaintiff failed to show a right to relief. The magistrate recommended dismissal pursuant to Civ.R. 41(B)(2). | Peterson | |
9/12/2025
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10/16/2025
| 2025-Ohio-4748 |
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Mash v. Union Cty. Sheriff's Office
| 2025-00514PQ | Public Records; R.C. 149.43(A)(2)(c); the Investigatory work product exception codified in R.C. 149.43(A)(2)(c) no longer applies once the statute of limitations for the crime investigated has expired. | Marti | |
9/11/2025
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10/20/2025
| 2025-Ohio-4790 |
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McCurley v. W. Chester Twp.
| 2025-00470PQ | Public Records; R.C. 149.43(B)(1); Reference to unproduced attachments in an email that has been produced is some evidence that the attachments exist. | Marti | |
9/8/2025
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10/20/2025
| 2025-Ohio-4789 |
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Andrews v. Ohio Atty. Gen.
| 2024-00443JD | Civ.R. 56; motion for summary judgment; malicious prosecution. Defendants were entitled to judgment as a matter of law on plaintiffs’ malicious prosecution claims because the grand jury indictments created a rebuttable presumption that probable cause existed to prosecute plaintiffs, and plaintiffs failed to rebut that presumption. In addition, plaintiffs were unable to demonstrate that the underlying criminal proceedings were terminated in their favor. Accordingly, their malicious prosecution claims failed as a matter of law. Judgment for defendants. | Sadler | |
9/5/2025
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10/16/2025
| 2025-Ohio-4746 |
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Pitzer v. Montgomery Cty. Coroner's Office
| 2025-00591PQ | Public Records; R.C. 313.10(A); The coroner of the county where a death is pronounced has exclusive responsibility for public records regarding that death, including records held by another county’s coroner. | Marti | |
9/2/2025
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10/20/2025
| 2025-Ohio-4791 |
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Racano v. Ohio Dept. of Transp.
| 2025-00478AD | Ohio Department of Transportation; pothole; rental car; Uber ride; collision deductible. Judgment for plaintiff. | Shaver | |
8/27/2025
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9/9/2025
| 2025-Ohio-3236 |
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Kearns v. Elyria Police Dept.
| 2025-00387PQ | Public Records; R.C. 149.43(A)(1) and (3); R.C. 149.43(A)(17)(i); R.C.1337.11; An ambulance is not a health care facility for purposes of R.C. 149.43(A)(17)(i) and R.C.1337.11; recordings of EMTs treating persons are medical records within the meaning of R.C. 149.43(A)(1) and (3). | Marti | |
8/27/2025
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9/15/2025
| 2025-Ohio-4334 |
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Lyrenmann v. Milford Exempted Village Schools
| 2025-00570PQ | Public Records; R.C. 149.011(G); R.C. 149.43(B)(1); R.C. 3319.321; The definition of “personally Identifiable information“ provided in 34 C.F.R. § 99.3 defines that term for purposes of R.C. 3319.321; a public office may redact material that does not constitute a record within the meaning of R.C. 149.011(G); a requester challenging a redaction based on the redacted material not constituting a record has the burden of proving that the redacted material is a record. | Sadler | |
8/27/2025
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9/15/2025
| 2025-Ohio-4335 |
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Wysong v. Dayton City Hall
| 2025-00002PQ | On filings submitted by the parties, the Court determined that Respondent had substantially complied with certain orders of the Court. The Court denied Requester’s application for the Court to retain jurisdiction in this case. | Sadler | |
8/26/2025
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9/15/2025
| 2025-Ohio-4329 |
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Deitz v. Shelby Cty. Prosecutor's Office
| 2025-00339PQ | Public records; R.C. 149.43(C); R.C. 2743.75(F)(3); statutory damages. The Court overruled requester’s objection because statutory damages are not available for public records cases filed in the Court of Claims under R.C. 149.43(C)(3). | Sadler | |
8/26/2025
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9/15/2025
| 2025-Ohio-4332 |
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Forhan v. Ohio House of Representatives
| 2025-00596PQ | Public Records; R.C. 2743.75; a requester suing under R.C. 2743.75 has the burden of proving that the materials sought have the constituent elements of a public record if any of those elements are disputed. | Marti | |
8/26/2025
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9/15/2025
| 2025-Ohio-4336 |
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Joy v. New Lebanon
| 2025-00616PQ | Public Records; R.C. 149.43(A)(1)(v); Attorney-client Privilege; the attorney-client privilege applies against directors and other individual constituents of an organizational client; the principles governing the representation of organizational clients apply to the representation of governmental organizations. | Marti | |
8/21/2025
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9/15/2025
| 2025-Ohio-4337 |
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Cook v. Ohio Dept. of Rehab. & Corr.
| 2025-00145AD | Inmate; property loss; bailment; negligence. Judgment for defendant. | Shaver | |
8/13/2025
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9/9/2025
| 2025-Ohio-3228 |
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Hanson v. Etna Twp.
| 2025-00243PQ | Public Records. | Sadler | |
8/12/2025
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9/15/2025
| 2025-Ohio-4331 |
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Ackley v. Washington Court House Police Dept.
| 2025-00351PQ | Public Records. | Sadler | |
8/12/2025
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9/15/2025
| 2025-Ohio-4333 |
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Ealom v. Ohio Dept. of Rehab. & Corr.
| 2024-00024JD | Negligence; 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
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9/4/2025
| 2025-Ohio-3141 |
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Dye v. Cleveland
| 2025-00216PQ | Public records; metadata; existence of records. The Court overruled requester’s objections and adopted the special master’s report and recommendation because metadata must be specifically requested in the initial request and requester did not prove by clear and convincing evidence that records exist that were not produced. | Sadler | |
8/6/2025
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9/15/2025
| 2025-Ohio-4330 |
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Deitz v. Shelby Cty. Pros. Office
| 2025-00339PQ | Public 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
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8/14/2025
| 2025-Ohio-2881 |
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In re J.S.
| 2025-00179VI | Victims 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
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9/9/2025
| 2025-Ohio-3230 |
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Lyrenmann v. Milford Exempted Village Schools
| 2025-00570PQ | Public 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
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8/14/2025
| 2025-Ohio-2885 |
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Porter v. Ohio Dept. of Rehab. & Corr.
| 2025-00155AD | Inmate; property loss; bailment; negligence; damages. Judgment for plaintiff. | Shaver | |
7/29/2025
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9/9/2025
| 2025-Ohio-3229 |
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Ackley v. Washington Court House Police Dept.
| 2025-00351PQ | Public 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
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8/14/2025
| 2025-Ohio-2882 |
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White v. Ross Corr. Inst.
| 2025-00474PQ | 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. | Marti | |
7/22/2025
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8/14/2025
| 2025-Ohio-2884 |
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In re Darling
| 2025-00213VI | Victims of crime. No objections filed. Magistrate’s decision adopted. Applicant’s claim denied. | Sadler | |
7/17/2025
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9/9/2025
| 2025-Ohio-3232 |
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In re Darling
| 2025-00214VI | Victims of crime. No objections filed. Magistrate’s decision adopted. Applicant’s claim denied. | Sadler | |
7/17/2025
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9/9/2025
| 2025-Ohio-3239 |
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In re J.S.
| 2025-00179VI | Victims 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
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9/9/2025
| 2025-Ohio-3231 |
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Hanson v. Etna Twp.
| 2025-00243PQ | Public 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
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8/14/2025
| 2025-Ohio-2880 |
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In re McCoy
| 2023-00640VI | Victims of crime. Objections overruled. Magistrate’s decision adopted. Applicant’s claim granted. | Sadler | |
7/10/2025
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9/9/2025
| 2025-Ohio-3205 |
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In re Powell
| 2024-00165VI | Victims 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
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9/9/2025
| 2025-Ohio-3207 |
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Trader v. Ontario Local School Dist.
| 2025-00123PQ | Public Records. | Sadler | |
7/9/2025
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8/14/2025
| 2025-Ohio-2879 |
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Kidd v. Wilmington
| 2025-00620PQ, 2025-00621PQ, 2025-00622PQ, 2025-00623PQ, 2025-00624PQ, 2025-00625PQ, 2025-00626PQ, 2025-00627PQ, 2025-00628PQ | Public 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
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8/14/2025
| 2025-Ohio-2886 |
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Kidd v. Wilmington
| 2025-00620PQ, 2025-00621PQ, 2025-00622PQ, 2025-00623PQ, 2025-00624PQ, 2025-00625PQ, 2025-00626PQ, 2025-00627PQ, 2025-00628PQ | Public 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
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8/14/2025
| 2025-Ohio-2887 |
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Owens v. Ohio Dept. of Rehab. & Corr.
| 2025-00011AD | Inmate; property loss; bailment; contraband; JPay tablets; negligence; discretionary immunity. Judgment for plaintiff. | Shaver | |
7/8/2025
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9/9/2025
| 2025-Ohio-3225 |
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Weaver v. Ohio Dept. of Pub. Safety
| 2023-00573JD | Motion 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
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8/18/2025
| 2025-Ohio-2916 |
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Johnson v. Ohio Dept. of Rehab. & Corr.
| 2024-00618JD | Civ.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
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8/18/2025
| 2025-Ohio-2919 |
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In re Darling
| 2025-00213VI | Victims 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
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9/9/2025
| 2025-Ohio-3233 |
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In re Darling
| 2025-00214VI | Victims 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
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9/9/2025
| 2025-Ohio-3235 |
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O'Brien v. Ohio Bur. of Workers' Comp.
| 2023-00659JD | Motion 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
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8/18/2025
| 2025-Ohio-2918 |
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Welch v. Ohio Dept. of Rehab. & Corr.
| 2023-00655JD | Civ.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
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7/17/2025
| 2025-Ohio-2514 |
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In re Powell
| 2024-00165VI | Victims 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
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9/9/2025
| 2025-Ohio-3208 |
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Marquette v. Ohio Univ.
| 2024-00676AD | Student; 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
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9/9/2025
| 2025-Ohio-3218 |
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Bowen v. Ohio Univ.
| 2024-00880AD | Student; dorm room; safety rail; top bunk bed; concussion; negligence; damages. Judgment for plaintiff. | Shaver | |
6/25/2025
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9/9/2025
| 2025-Ohio-3224 |
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Gibson v. Ohio Dept. of Rehab. & Corr.
| 2024-00862AD | Inmate; property loss; bailment; possession; negligence. Judgment for defendant. | Shaver | |
6/25/2025
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9/9/2025
| 2025-Ohio-3238 |
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Kearns v. Fairfield Police Dept.
| 2025-00017PQ | Public Records. | Sadler | |
6/17/2025
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7/3/2025
| 2025-Ohio-2373 |
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Trader v. Ontario Local School Dist.
| 2025-00123PQ | Public 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
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7/3/2025
| 2025-Ohio-2374 |
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