State ex rel. Dayton Newspapers, Inc. v. Rauch

R.C. 149.43(B) requires the disclosure of all public records. Respondent contends that autopsy reports on homicide victims are exempt from disclosure as confidential law enforcement records because their release would disclose “[s]pecific confidential investigatory techniques or procedures or specific investigatory work product.” R.C. 149.43(A)(2)(c).

In support of this contention respondent states that the autopsy reports contain information relating to the type of wounds, how they were inflicted, etc., which aid law enforcement personnel in conducting their investigation. Respondent also…