State ex rel. James v. Ohio State University

At issue in this case is whether documents contained in promotion and tenure files maintained by the university are public records subject to disclosure under R.C. 149.43(B), or whether the records meet any of the exceptions contained in R.C. 149.43(A)(1) so as to prevent disclosure.

The university does not dispute that it is a state agency and public office under R.C. 149.011. Rather, it argues that the records are excepted from disclosure under R.C. 149.43(A)(1). In considering the university’s arguments, we are mindful that exceptions to disclosure are to be construed strictly against the…