State ex rel. McGee v. Ohio State Board of Psychology

Ohio’s public records statute mandates release of public records, but explicitly excepts “confidential law enforcement investigatory records.” R.C. 149.43(A)(2), inter alia, provides:

“ ‘Confidential law enforcement investigatory record’ means any record that pertains to a law enforcement matter of a criminal, quasi-criminal, civil, or administrative nature, but only to the extent that the release of the record would create a high probability of disclosure of any of the following:

“(a) The identity of a suspect who has not been charged with the offense to which the record pertains, or of an…