State ex rel. Hamblin v. City of Brooklyn

We hold that the court of appeals did not abuse its discretion in finding particular witness statements to be exempt trial preparation materials under R.C. 149.43(A)(4) or in finding certain forensic documents to be exempt investigatory work product, R.C. 149.43(A)(2)(c).

Here, the court of appeals performed the mandated individualized scrutiny of the records. See State ex rel. Natl. Broadcasting Co. v. Cleveland (1988), 38 Ohio St.3d 79, 526 N.E.2d 786; State ex rel. Natl. Broadcasting Co. v. Cleveland (1991), 57 Ohio St.3d 77, 566 N.E.2d 146. Previously, we chose to defer to the discretion…