State ex rel. Miller v. Pinkney

Summary

The Supreme Court of Ohio considered a mandamus action seeking offense and incident reports under Ohio's Public Records Act. The court held that certain routine incident reports were not security records and ordered their release with redactions, granting the writ in part and denying it in part.

Holdings

1. Routine offense and incident reports are public records normally subject to immediate release upon request.
2. The incident reports dated May 1, 2012; June 1, 2012; September 26, 2012; March 18, 2013; October 1, 2013; April 24, 2014; May 14, 2014; August 2, 2014; and August 27, 2014 were not security records and were subject to release with redaction of exempt information.
3. The writ of mandamus was granted in part and denied in part, and Miller was awarded costs and reasonable attorney fees subject to determination after review of his itemized application.

Questions Presented

1. Whether routine offense and incident reports responsive to Miller's request were public records subject to disclosure under Ohio's Public Records Act.
2. Whether the responsive records qualified as security records exempt from mandatory disclosure under R.C. 149.433.
3. Whether Miller was entitled to a writ of mandamus, costs, and reasonable attorney fees.

Disposition

other