uncharged-suspect exception (Ohio) · Go Syfert
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uncharged-suspect exception in Ohio

10 Ohio opinions name it 3 courts 1996–2026 3 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (1)

CaseFollowedCited
State ex rel. Master v. City of Clevelandgreen
ohio · 1996 · cited in 6 Ohio opinions naming this issue, 1996–2026
2 sentences

2024There is no evidence that proves a criminal act occurred and as such, . . . an uncharged suspect interview cannot be released as it does not constitute a public record under Ohio law." "The uncharged suspect exception applies despite the passage of time, the lack of enforcement action, or a prosecutor's decision not to file formal charges." Master, 75 Ohio St.3d at 30 .

2023Master v. Cleveland, 75 Ohio St.3d 23, 30 , 661 N.E.2d 180 (1996) (“The uncharged-suspect exception applies despite the passage of time, the lack of enforcement action, or a prosecutor’s decision not to file formal charges”). {¶ 38} We deny statutory damages as to the disclosure of the packet of records and the videos. 2.

16

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
State ex rel. Master v. City of Cleveland green
ohio · 1996
2 sentences

2026Master v. Cleveland (1996), 76 Ohio St.3d 340, 342 , 1996 Ohio 300 , 667 N.E.2d 974 . {¶17} In the Report and Recommendation at 6, the Special Master made certain findings, I … find that the Police Division appropriately withheld the bulk of the investigative file pursuant to the CLEIR work product exception.

2026Master v. Cleveland (1996), 76 Ohio St.3d 340, 342 , 1996 Ohio 300 , 667 N.E.2d 974 . {¶17} In the Report and Recommendation at 6, the Special Master made certain findings, I … find that the Police Division appropriately withheld the bulk of the investigative file pursuant to the CLEIR work product exception.

22010–2026
State ex rel. Ohio Patrolmen's Benevolent Ass'n v. City of Mentor green
ohio · 2000
2 sentences

2024Ohio Patrolmen's Benevolent Assn. v. Mentor, 89 Ohio St.3d 440, 447 , 2000-Ohio-214 . {¶ 23} The trial court did not err in exempting the video interviews of Mike Hartley and Brandon Reed from disclosure under R.C. 149.43(A)(2)(a) because the City clearly established the applicability of the uncharged-suspect exception.

2010Ohio Patrolmen’s Benevolent Assn. v. Mentor (2000), 89 Ohio St.3d 440, 444 , 732 N.E.2d 969 . {¶ 29} With respect to the first criterion, records compiled by the board while investigating whether a physician violated R.C.

22010–2024
State ex rel. Moreland v. City of Dayton green
ohio · 1993
2 sentences

1996Moreland, supra, 67 Ohio St.3d at 130-131 , 616 N.E.2d at 236 ; State ex rel.

1996Moreland, supra, 67 Ohio St.3d at 130-131 , 616 N.E.2d at 236 ; State ex rel.

21996–1996
State ex rel. Master v. Cleveland green
ohio · 1996
1 sentence

2026Master v. Cleveland (1996), 75 Ohio St.3d 23, 30 , 1996 Ohio 228 , 661 N.E.2d 180 .

12026–2026
State Ex Rel. Rocker v. Guernsey County Sheriff's Office green
ohio · 2010
1 sentence

2026Sheriff’s Office, 2010-Ohio-3288, ¶ 10-11 , the Supreme Court of Ohio noted: “The uncharged suspect exception applies despite the passage of time, the lack of enforcement action, or a prosecutor’s decision not to file formal charges.” State ex rel.

12026–2026
State ex rel. Master v. Cleveland neutral
ohio · 1996
1 sentence

2026Master v. Cleveland (1996), 76 Ohio St.3d 340, 342 , 1996 Ohio 300 , 667 N.E.2d 974 . {¶17} In the Report and Recommendation at 6, the Special Master made certain findings, I … find that the Police Division appropriately withheld the bulk of the investigative file pursuant to the CLEIR work product exception.

12026–2026
State ex rel. Ohio Patrolmen's Benevolent Assn. v. Mentor neutral
ohio · 2000
1 sentence

2024Ohio Patrolmen's Benevolent Assn. v. Mentor, 89 Ohio St.3d 440, 447 , 2000-Ohio-214 . {¶ 23} The trial court did not err in exempting the video interviews of Mike Hartley and Brandon Reed from disclosure under R.C. 149.43(A)(2)(a) because the City clearly established the applicability of the uncharged-suspect exception.

12024–2024
State ex rel. Patton v. Rhodes green
ohio · 2011
1 sentence

2024"In the -6- Clinton CA2024-02-002 absence of evidence to the contrary, public officers, administrative officers and public boards, within the limits of the jurisdiction conferred by law, will be presumed to have properly performed their duties and not to have acted illegally but regularly and in a lawful manner." Id. {¶ 17} Pitzer's second assignment of error is overruled. {¶ 18} Assignment of Error No. 1: {¶ 19} THE INTERVIEWS OF THE SUSPECTS DURING THE INVESTIGATION INTO CASEY PITZER'S DEATH ARE NOT EXEMPT UNDER THE UNCHARGED SUSPECT EXCEPTION. {¶ 20} Pitzer argues the trial court erred in f

12024–2024
State ex rel. Beacon Journal Publishing Co. v. Maurer green
ohio · 2001
1 sentence

2023Fluty admits that Broadview Heights cited the uncharged-suspect exception but faults it for relying on this exception because Maurer, 91 Ohio St.3d 54 , 741 N.E.2d 511 , “makes clear that that exemption is not a legal authority to withhold the report.” Even if Maurer’s core holding were still good law, Fluty’s argument fails because the 12 January Term, 2023 Public Records Act does not authorize an award of statutory damages merely because a public office cites legal authority with which the requester disagrees. {¶ 40} Fluty also argues that Broadview Heights failed to provide her with a valid

12023–2023
Barton v. Shupe green
ohio · 1988
2 sentences

1997The present case is distinguishable from relevant cases cited by Strothers: NBC; Snowden; Barton v. Shupe (1988), 37 Ohio St.3d 308 , 525 N.E.2d 812 ; *334 State ex rel.

1997The present case is distinguishable from relevant cases cited by Strothers: NBC; Snowden; Barton v. Shupe (1988), 37 Ohio St.3d 308 , 525 N.E.2d 812 ; *334 State ex rel.

11997–1997

Statutes the citing opinions construe

OH § Ohio Rev. Code § 149.43 (10)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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