State ex rel. Plain Dealer Publishing Co. v. Lesak

The issue is whether the banking records pertaining to the two illicit checking accounts are public records pursuant to R.C. 149.43. For the reasons that follow we affirm the court of appeals’ decision to compel disclosure of these records.

Public records must be available and open to inspection within a reasonable period of time pursuant to R.C. 149.43(B). The test for public records is twofold. First, the records must be kept by a governmental unit. Second, the records must be specifically required to be kept by law. State, ex rel. Citizens’ Bar Assn., v. Gagliardo (1978), 55 Ohio St. 2d 70…