A court of appeals properly denied a newspaper’s public records request for the names and identifying information of police officers involved in a shootout with a motorcycle gang, under the Public Records Act’s privacy exception (Ohio Revised Code § 149.43(A)(1)(v)), because the motorcycle gang could use the information to retaliate. State ex rel. Cincinnati Enquirer v. Craig, 2012-Ohio-1999 (Ohio Supreme Court).
A non-civil-service township peace officer who has been certified as a peace officer under Ohio Revised Code § 109.77 and is appointed police chief and then terminated for a reason other than cause does not have a right to return to the position he held before his appointment as police chief, as Ohio Revised Code § 505.49(C) is inapplicable. Blair v. Sugarcreek Twp. Bd. of Trustees, 2012- Ohio-2165 (Ohio Supreme Court).
A limited-home-rule township created under Ohio Revised Code § 504.04(A)(1) may not impose impact fees on applicants for zoning certificates for new construction or redevelopment, because those fees would constitute a tax not authorized by general law. Drees Co. v. Hamilton Twp., 2012- Ohio-2370 (Ohio Supreme Court).
Although a nonprofit corporation that leases a public market from a city and manages the public market for the city is considered a person responsible for public records under the Public Records Act, the specific terms of the commercial leases between the public market and its tenants constitute trade secrets, which are exempt from disclosure under Ohio Revised Code § 149.43(A)(1)(v). State ex rel. Luken v. Corp. for Findlay Mkt. of Cincinnati, 2012-Ohio-2074 (Ohio App. 1st Dist.).
The trial court erred in holding that “in order to demonstrate that the Board was conferencing with its attorney concerning disputes involving the public body that were the subject of imminent court action [and, thus, allowed to convene an executive session under Ohio Revised Code § 121.22(G)(3)], direct evidence that there was a dispute involving the public body that was the subject of imminent court action is required.” State ex rel. Hardin v. Clermont Cty. Bd. of Elections, 2012-Ohio-2569 (Ohio App. 12th Dist.).
A public body that attempts to enter into executive session with a motion and vote stating, without further explanation, that the session is being entered into to discuss a “personal matter” was not specific enough to satisfy the requirements of Ohio Revised Code § 121.22(G)(1) that the motion and vote to hold an executive session state which one or more of the approved purposes listed in Ohio Revised Code § 121.22(G)(1) are the purposes for which the executive session is to be held. 2012 Op. Att’y General No. 2012-022.