State ex rel. Martin v. City of Cleveland

We affirm the court of appeals’ decision to exempt documents from public release based upon promises of confidentiality or threats to the physical safety of witnesses. See R.C. 149.43(A)(2)(b) and (d). We also affirm that court’s finding that certain witness statements were exempt from release as “trial preparation records” under R.C. 149.43(A)(4).

At the outset, we reject Martin’s effort to require that a public document, within its four corners, specify the promise of confidentiality to witnesses or the threat to their physical safety in order to be exempt from release under R.C.…