This case was a public-records action in which relator, ESPN, Inc., sought certain records from respondent, Ohio State University. Ohio State rejected ESPN's requests because the university deemed them to be "overly broad per Ohio's public record laws." EPSN then filed this action for a writ of mandamus to compel Ohio State to provide access to the requested records. The Supreme Court (1) granted the writ for limited records that should have been disclosed because they were not exempt from disclosure based on the Family Educational Rights and Privacy Act (FERPA); but (2) denied the writ for the rest of the records because Ohio State established that FERPA and the attorney-client privilege prohibited the disclosure of the requested records. View "State ex rel. ESPN, Inc. v. Ohio State Univ." on Justia Law
Appellant, inmate Sidney Souffrance, petitioned the court of appeals for a writ of mandamus to compel Appellee, the records custodian for the Life Skills Center of Cincinnati, a community school, to provide access to the attendance records, addresses, and telephone numbers of all students who were in a certain classroom during two specific months and to records indicating which computer terminal a specific student had used during one of those months. The court of appeals held that the disclosure of the requested records was barred by the Family Educational Rights and Privacy Act (FERPA). The Supreme Court affirmed, holding that although the record request related to persons who were no longer students, because the persons were students when the records were created and originally maintained, the records were subject to the nondisclosure provisions of FERPA. View "State ex rel. Souffrance v. Doe" on Justia Law
After she was told in advance that her contract for employment would not be renewed, Stacey Carna, the principal of an elementary school, requested a meeting with the school board to discuss the nonrenewal of her contract. Without meeting with Carna, the board voted not to renew Carna's contract. The common pleas court denied Carna's subsequent request for mandamus relief, and the court of appeals affirmed. The Supreme Court reversed, holding that after an administrator has been informed that her contract will not be renewed, upon the administrator's request for a meeting with the school board to discuss the nonrenewal of her contract, Ohio Rev. Code 3319.02(D)(4) requires the board to meet in executive session with the administrator to discuss the reasons for nonrenewal. Remanded. View "State ex rel. Carna v. Teays Valley Local Sch. Dist. Bd. of Educ." on Justia Law
Posted in: Education Law, Government & Administrative Law, Labor & Employment Law, Ohio Supreme Court
In an underlying civil case, Appellant filed a notice of dismissal, voluntarily dismissing the case without prejudice. Minutes later, a deputy clerk responsible for processing the queue of electronically transmitted documents clicked on the court of common pleas judge's journal entry granting summary judgment in favor of the respondents, which had been transmitted earlier that day. The judge subsequently struck Appellant's notice of dismissal and held that the summary judgment was the final judgment on the merits of the case. Appellant requested a writ of prohibition and a writ of mandamus, which the court of appeals denied. The Supreme Court reversed in part, holding that the court of appeals erred in denying Appellant's request for (1) a writ of prohibition to prevent the judge from proceeding on the merits of the underlying case where the judge lacked jurisdiction because, pursuant to Ohio R. Civ. P. 58(A), the entry of summary judgment was not effective until after Appellant's notice of dismissal; and (2) a writ of mandamus to compel the judge to vacate her entry striking the notice of dismissal and her entry of summary judgment in the underlying case and to compel the judge to reinstate her notice of dismissal. View "State ex rel. Engelhart v. Russo" on Justia Law
Relator, Angela Dawson, requested a writ of mandamus to compel Respondent, a local school district, to provide her with access to (1) itemized invoices of law firms providing services to the district in matters pertaining to Dawson and her children, and (2) communications from the school district's insurance carrier identifying the district's legal representative and describing the liability and exposure of the district and insurance company related to a case filed against the district by Dawson on behalf of one of her children. The Supreme Court denied the writ, holding that the requested records were exempt from disclosure under the Public Records Act because the school district met its burden of establishing the applicability of the attorney-client privilege to the requested records. View "State ex rel. Dawson v. Bloom-Carroll Local Sch. Dist." on Justia Law
The German Village Society (GVS) filed an application for exemption of real property. Pursuant to Ohio Rev. Code 5715.27(C), the school board became a party to the proceedings before the tax commission and to any appeal to the Board of Tax Appeals (BTA). After the tax commissioner denied GVS's application, GVS appealed to the BTA but did not serve the school board with its notice of appeal. BTA reversed the decision of the tax commissioner and granted the exemption but did not transmit its decision to the school board. The tax commissioner then issued a determination giving effect to the BTA's decision. The school board filed a notice of appeal from the tax commissioner's order, asserting that the BTA's decision was void ab initio because the school board was not named or notified as to the existence of the appeal. The BTA held that because the period for appeal from its decision had expired, it did not have jurisdiction to address the validity of its earlier decision. The Supreme Court reversed the BTA's holding that it had no jurisdiction to grant relief to the school board, vacated the BTA's decision along with the tax commissioner's related order, and remanded.