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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.
| Case | Followed | Cited |
|---|---|---|
State ex rel. Master v. City of Clevelandgreen2 sentences2024There 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. | 1 | 6 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State ex rel. Master v. City of Cleveland
green
2 sentences2026Master 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. | 2 | 2010–2026 |
State ex rel. Ohio Patrolmen's Benevolent Ass'n v. City of Mentor
green
2 sentences2024Ohio 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. | 2 | 2010–2024 |
State ex rel. Moreland v. City of Dayton
green
2 sentences1996Moreland, 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. | 2 | 1996–1996 |
State ex rel. Master v. Cleveland
green
1 sentence2026Master v. Cleveland (1996), 75 Ohio St.3d 23, 30 , 1996 Ohio 228 , 661 N.E.2d 180 . | 1 | 2026–2026 |
State Ex Rel. Rocker v. Guernsey County Sheriff's Office
green
1 sentence2026Sheriff’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. | 1 | 2026–2026 |
State ex rel. Master v. Cleveland
neutral
1 sentence2026Master 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. | 1 | 2026–2026 |
State ex rel. Ohio Patrolmen's Benevolent Assn. v. Mentor
neutral
1 sentence2024Ohio 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. | 1 | 2024–2024 |
State ex rel. Patton v. Rhodes
green
1 sentence2024"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 | 1 | 2024–2024 |
State ex rel. Beacon Journal Publishing Co. v. Maurer
green
1 sentence2023Fluty 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 | 1 | 2023–2023 |
Barton v. Shupe
green
2 sentences1997The 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. | 1 | 1997–1997 |
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.