State ex rel. Fant v. Enright

Appellant raises one issue on appeal: whether a person may inspect and copy a “public record,” as defined in R.C. 149.43(A)(1), irrespective of his or her purpose for doing so. We answer in the affirmative and reverse the judgment of the court of appeals.

The court of appeals held that appellant had not “presented] any proper purpose justifying disclosure pursuant to law.” The idea that a proper purpose is required to obtain a public record derives from our decision in the Wooster Republican case, supra. In that case, we devised a test to balance the requirements of the Privacy Act, R.C.…