State ex rel. Zuern v. Leis

We find that the court of appeals did not abuse its discretion in finding that the sheriff’s department’s homicide investigative file did not qualify as an exempt “trial preparation record” under R.C. 149.43(A)(4). Further, we find that respondents waived any possible exemption to public release of the records by voluntarily disclosing them in the Pence case. Hence, we affirm the judgment of the court of appeals.

In their two propositions of law, respondents argue for a broad interpretation of the “trial preparation *21record” exemption to R.C. 149.43, which mandates release of public records.…