State ex rel. Clark v. City of Toledo

Clark now asserts that the court of appeals erred in conducting its in camera review. We hold that the court of appeals did not abuse its discretion in how it conducted an in camera inspection of disputed public records. We therefore affirm.

In his first proposition of law, Clark argues that the lower court erred when it failed to individually describe each document and specify why each particular document was exempt. We reject that proposition.

Application of a statutory exemption to a particular document is best done by an in camera inspection. Henneman v. Toledo (1988), 35 Ohio St.3d 241,…