Ohio Rev. Code » Chapter 149
Ohio Revised Code

Ohio Rev. Code § 149.011 (2026)

Documents, reports, and records definitions

✓ laws through the 2026 session (checked Sept. 2026)
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Effective:
September 30, 2025
Latest Legislation:
House Bill 96 - 136th General Assembly
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As used in this chapter, except as otherwise provided:

(A) "Public office" includes any state agency, public institution, political subdivision, or other organized body, office, agency, institution, or entity established by the laws of this state for the exercise of any function of government. "Public office" does not include the nonprofit corporation formed under section 187.01 of the Revised Code.

(B) "State agency" includes every department, bureau, board, commission, office, or other organized body established by the constitution and laws of this state for the exercise of any function of state government, including any state-supported institution of higher education, the general assembly, any legislative agency, any court or judicial agency, or any political subdivision or agency of a political subdivision. "State agency" does not include the nonprofit corporation formed under section 187.01 of the Revised Code.

(C) "Public money" includes all money received or collected by or due a public official, whether in accordance with or under authority of any law, ordinance, resolution, or order, under color of office, or otherwise. It also includes any money collected by any individual on behalf of a public office or as a purported representative or agent of the public office.

(D) "Public official" includes all officers, employees, or duly authorized representatives or agents of a public office.

(E) "Color of office" includes any act purported or alleged to be done under any law, ordinance, resolution, order, or other pretension to official right, power, or authority.

(F) "Archive" includes any public record that is transferred to the state archives or other designated archival institutions because of the historical information contained on it.

(G) "Records" includes any document, device, or item, regardless of physical form or characteristic, including an electronic record as defined in section 1306.01 of the Revised Code, created or received by or coming under the jurisdiction of any public office of the state or its political subdivisions, which serves to document the organization, functions, policies, decisions, procedures, operations, or other activities of the office. "Records" does not include personal notes or any document, device, or item, regardless of physical form or whether an assistive device or application was used, of a public official, or of the official's attorney, employee, or agent, that is used, maintained, and accessed solely by the individual who creates it or causes its creation.

Last updated July 17, 2025 at 11:42 AM

Notes of Decisions
Cited in 232 cases (100 in the last 5 years), 1988–2026 · leading case: State ex rel. Dispatch Printing Co. v. Johnson, 106 Ohio St. 3d 160 (2005).
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State ex rel. Dispatch Printing Co. v. Johnson, 106 Ohio St. 3d 160 (2005). · cites it 23× “Retirees was decided six years before R.C. 149.011 was first enacted, and that statute had been effective for only 16 days when Police & Fire Retirees was decided.”
Kish v. City of Akron, 109 Ohio St. 3d 162 (2006). · cites it 14× “011, may be a single document within a larger file of documents as well as a compilation of documents, and can be any document, regardless of physical form or characteristic, whether in draft, compiled, raw, or refined form, that is created or received or used by a public office…”
State ex rel. Strothers v. Wertheim, 684 N.E.2d 1239 (Ohio 1997). · cites it 24× “, Toledo Blade, at paragraph one of the syllabus (“A private nonprofit corporation that acts as a major gift-receiving and soliciting arm of a public university and receives support from public taxation is a ‘public office’ pursuant to R.C. 149.011[A], and is subject to the…”
State ex rel. Teagarden v. Igwe, 2024-Ohio-5772, 262 N.E.3d 354. · cites it 26× “But the illustrative lists in R.C. 149.011 do not include any natural persons; they include only inanimate governmental bodies.”
Hicks v. Union Twp., 2023-Ohio-874. · cites it 25× “{¶44} I agree with the majority that both the email and mail distribution lists are "documents, devices, or items" under the jurisdiction of the Township and that the issue in this appeal concerns whether the email and mail distribution lists serve to document the "functions,…”
Doe v. Ohio State Univ., 2024-Ohio-5891, 261 N.E.3d 1. · cites it 23× “Ohio State notified Doe that the spreadsheet omitted the employees’ home mailing addresses and personal email addresses because neither home mailing addresses nor personal email addresses constituted records under R.C. 149.011(G). Doe then supplemented his first request by…”
State ex rel. Toledo Blade Co. v. Univ. of Toledo Found., 602 N.E.2d 1159 (Ohio 1992). · cites it 14× “This case presents two related issues: (1) whether the foundation is a “public office” pursuant to R.C. 149.011(A) and thus subject to the open-records requirements of R.”
Hicks v. Union Twp. Clermont Cty. Bd. of Trs., 2024-Ohio-5449, 255 N.E.3d 38. · cites it 18× “or other activities of the office,” R.C. 149.011(G), so they are subject to disclosure.”
Hurt v. Liberty Twp., 2017-Ohio-7820, 97 N.E.3d 1153. · cites it 4× “{¶ 67} R.C. 149.011 defines the term "record" as follows, (G) "Records" includes any document, device, or item, regardless of physical form or characteristic, including an electronic record as defined in section 1306.”
State ex rel. Data Trace Info. Servs., L.L.C. v. Cuyahoga Cnty. Fiscal Officer, 2012-Ohio-753, 131 Ohio St. 3d 255. · cites it 8× “” R.C. 149.011(G) provides that for R.C. Chapter 149, “[r]ecords” includes any document, device, or item, regardless of physical form or characteristic, including an electronic record as defined in section 1306.”
State ex rel. Am. Civil Liberties Union of Ohio, Inc. v. Cuyahoga Cnty. Bd. of Commissioners, 2011-Ohio-625, 128 Ohio St. 3d 256. · cites it 7× “22(B)(4), which provides that “ ‘[p]ublic office’ has the same meaning as in section 149.011 of the Revised Code.” Had the General Assembly intended that a “public body” for purposes of R.”
State ex rel. Beacon Journal Publ'g Co. v. Whitmore, 697 N.E.2d 640 (Ohio 1998). · cites it 16× “” R.C. 149.011(A) and (B). R.C. 149.011(G) defines “records” broadly to include “any document, device, or item, regardless of physical form or characteristic, created or received by or coming under the jurisdiction of any •public office of the state or its political…”
Show all 232 citing cases →
Ohio Rev. Code § 149.011(A): 99 cases
State ex rel. Strothers v. Wertheim, 684 N.E.2d 1239 (Ohio 1997). “, Toledo Blade, at paragraph one of the syllabus (“A private nonprofit corporation that acts as a major gift-receiving and soliciting arm of a public university and receives support from public taxation is a ‘public office’ pursuant to R.C. 149.011[A], and is subject to the…”
State ex rel. Toledo Blade Co. v. Univ. of Toledo Found., 602 N.E.2d 1159 (Ohio 1992). “This case presents two related issues: (1) whether the foundation is a “public office” pursuant to R.C. 149.011(A) and thus subject to the open-records requirements of R.”
State ex rel. Oriana House, Inc. v. Montgomery, 854 N.E.2d 193 (Ohio 2006).
State ex rel. Am. Civil Liberties Union of Ohio, Inc. v. Cuyahoga Cnty. Bd. of Commissioners, 2011-Ohio-625, 128 Ohio St. 3d 256. “22(B)(4), which provides that “ ‘[p]ublic office’ has the same meaning as in section 149.011 of the Revised Code.” Had the General Assembly intended that a “public body” for purposes of R.”
State ex rel. Repository v. Nova Behavioral Health, Inc., 2006-Ohio-6713, 859 N.E.2d 936.
Ohio Rev. Code § 149.011(B): 8 cases
State ex rel. Parker Bey v. Byrd (Slip Opinion), 2020-Ohio-2766, 154 N.E.3d 57.
State ex rel. Teagarden v. Igwe, 2024-Ohio-5772, 262 N.E.3d 354. “But the illustrative lists in R.C. 149.011 do not include any natural persons; they include only inanimate governmental bodies.”
State ex rel. Cincinnati Enquirer v. Jones-Kelley, 886 N.E.2d 206 (Ohio 2008).
State ex rel. Cincinnati Enquirer v. Forsthoefel, 2022-Ohio-3580, 212 N.E.3d 859.
State ex rel. Ware v. Kurt, 2022-Ohio-1627, 203 N.E.3d 665.
Ohio Rev. Code § 149.011(D): 12 cases
State ex rel. Teagarden v. Igwe, 2024-Ohio-5772, 262 N.E.3d 354. “But the illustrative lists in R.C. 149.011 do not include any natural persons; they include only inanimate governmental bodies.”
State ex rel. Ware v. Wine, 2022-Ohio-4472, 207 N.E.3d 807.
State ex rel. Cincinnati Enquirer v. Jones-Kelley, 886 N.E.2d 206 (Ohio 2008).
State ex rel. Glasgow v. Jones, 894 N.E.2d 686 (Ohio 2008).
State ex rel. Berry v. Booth, 2024-Ohio-5774, 262 N.E.3d 314.
Ohio Rev. Code § 149.011(G): 152 cases
State ex rel. Dispatch Printing Co. v. Johnson, 106 Ohio St. 3d 160 (2005). “Retirees was decided six years before R.C. 149.011 was first enacted, and that statute had been effective for only 16 days when Police & Fire Retirees was decided.”
Kish v. City of Akron, 109 Ohio St. 3d 162 (2006). “011, may be a single document within a larger file of documents as well as a compilation of documents, and can be any document, regardless of physical form or characteristic, whether in draft, compiled, raw, or refined form, that is created or received or used by a public office…”
Hicks v. Union Twp., 2023-Ohio-874. “{¶44} I agree with the majority that both the email and mail distribution lists are "documents, devices, or items" under the jurisdiction of the Township and that the issue in this appeal concerns whether the email and mail distribution lists serve to document the "functions,…”
Doe v. Ohio State Univ., 2024-Ohio-5891, 261 N.E.3d 1. “Ohio State notified Doe that the spreadsheet omitted the employees’ home mailing addresses and personal email addresses because neither home mailing addresses nor personal email addresses constituted records under R.C. 149.011(G). Doe then supplemented his first request by…”
Hicks v. Union Twp. Clermont Cty. Bd. of Trs., 2024-Ohio-5449, 255 N.E.3d 38. “or other activities of the office,” R.C. 149.011(G), so they are subject to disclosure.”
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