McEachron v. Garfield Hts.

Summary

The Ohio Court of Claims adopted a special master’s report and recommendation in a public-records case involving Orville McEachron and the City of Garfield Heights. The court granted the respondent’s motion to dismiss and ordered the requester to bear the costs because neither party filed timely objections and no error of law or facial defect was apparent.

Holdings

1. When neither party timely objects under R.C. 2743.75(F)(2), the Court of Claims must promptly issue a final order adopting the report and recommendation unless the court finds an error of law or other defect evident on the face of the report and recommendation.
2. The respondent's motion to dismiss was granted, and the requester was ordered to bear the costs of the case.

Questions Presented

1. Whether the Court of Claims should adopt the special master's report and recommendation when neither party timely objected under R.C. 2743.75(F)(2).
2. Whether the special master's recommendation contained an error of law or other defect evident on its face.

Disposition

dismissed