State ex rel. National Broadcasting Co. v. City of Cleveland

We hold that the court of appeals erred in finding these Cleveland police investigations did not create a “confidential law enforcement investigatory record” under R.C. 149.43(A)(2). We remand for an in camera inspection and redaction of protected information contained in these investigative files. We further hold the court of appeals did not err in declining to apply the “trial preparation record” exception under R.C. 149.43(A)(4), nor did it abuse its discretion in declining to award NBC attorney fees.

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Confidential Law Enforcement Investigatory Record

Cleveland argues that the court of…