Requester brought action against Ohio Legislative Service Commission (OLSC) seeking writ of mandamus to compel the disclosure, pursuant to the Public Records Act, of records related to the drafting of a bill that had been referred to a Senate committee and that pertained to local regulation and taxation of short-term rental properties, and also seeking a declaration that the statutory exemption for legislative documents from the Act’s definition of a “public record,” on which OLSC relied to withhold records, was unconstitutional as applied.
The Supreme Court held that:
- Statute exempting legislative documents from definition of a public record under the Act does not violate constitutional provision assuring public access to business transacted during General Assembly proceedings;
- Communications between legislative staff and individual members of General Assembly or General Assembly staff, which related to the bill were exempt from disclosure under the Act; and
- Requester did not provide clear and convincing evidence that OLSC withheld non-exempt records.