State ex rel. Cleveland Police Patrolmen's Ass'n v. City of Cleveland

CPPA asserts in its propositions of law that the court of appeals erred in concluding that most of the requested PCIR records were exempt from disclosure despite Officer Pettry’s agreement that she will not file an appeal or petition for postconviction relief. We agree with CPPA’s contention and reverse the judgment of the court of appeals.

Once they are determined to be exempt as trial-preparation records or work product, records continue to be exempt until all criminal proceedings are completed. State ex rel. Steckman v. Jackson (1994), 70 Ohio St.3d 420, 639 N.E.2d 83, paragraph four of the…