Ohio Attorney General releases 2015 Yellow Book

The Ohio Attorney General released the 2015 Sunshine Laws Manual (the Yellow Book) this week. The Yellow Book serves as a guide for Ohio’s public records and open meetings laws. Recent developments regarding the public records and open meetings laws included in the 2015 Yellow Book are:

• Ohio Appellate Court’s holding that informal email discussions among school board members, involving an issue of public concern, are not subject to the Open Meetings Act when not prearranged. White v. King, 2014 Ohio 3896.

• Ohio Attorney General opinion finding that personal email addresses that do not document the organization, the functions, policies, decisions, procedures, operations or other activities of the office are non-records and are not required to be disclosed. 2014 Ohio Op. Att’y Gen. No. 029.

• Ohio Appellate Court’s ruling that an officer’s cruiser camera video of a stop and investigation, and impaired driver report, is exempt from public disclosure as law enforcement investigatory work product. State ex. Rel. Miller v. Ohio State Hwy. Patrol, 2014-Ohio-2244.

• The Ohio Supreme Court’s ruling, in a case involving a newspaper company, that properly sealed records are exempt from release as public records. State ex rel. Cincinnati Enquirer v. Lyons, 140 Ohio St.3d 7, 2014-Ohio-2354.

The 2015 Yellow Book is a helpful resource for all political subdivisions in Ohio and is available for download on the Ohio Attorney General website.