State ex rel. Allright Parking of Cleveland, Inc. v. City of Cleveland

In the case now before us, the court of appeals ruled that ninety-four of the withheld documents were not excepted from disclosure as trade secrets because they had been submitted as part of an application under R.C. 1728.06 for approval of a tax-exempt project, and thus had become part of the public record. We hold it was error for the court of appeals to reach that conclusion without first reviewing the documents in question in camera to determine whether the documents had, in fact, become, part of the public record, and thus had lost their protection as trade secrets not subject to…