State ex rel. Besser v. Ohio State University

In reviewing the records withheld by OSU, the precept guiding our analysis is that the inherent, fundamental policy of R.C. 149.43 is to promote open government, not restrict it. State ex rel. The Miami Student v. Miami Univ. (1997), 79 Ohio St.3d 168, 171, 680 N.E.2d 956, 959. Consistent with this policy, exceptions to disclosure must be strictly construed against the public records custodian, and the custodian bears the burden to establish the applicability of an exception. State ex rel. McGowan v. Cuyahoga Metro. Hous. Auth. (1997) , 78 Ohio St.3d 518, 519, 678 N.E.2d 1388, 1389.

With these…