Kish v. City of Akron

{¶ 1} Pursuant to S.CLPrac.R. XVIII(6), we accepted these questions of state law certified by the United States Court of Appeals for the Sixth Circuit: “What constitutes a ‘record’ as that term is used in Ohio Rev.Code § 149.351?”1 Kish v. *163Akron, 102 Ohio St.3d 1529, 2004-Ohio-3580, 811 N.E.2d 1149, and “What constitutes a ‘violation’ as that term is used in Ohio Rev.Code § 149.351?” Kish v. Akron, 106 Ohio St.3d 1402, 2005-Ohio-3118, 829 N.E.2d 1215.

{¶ 2} We hold that “record,” as used in R.C. 149.351 and defined in R.C. 149.011, may be a single document within a larger file of documents as…