Daher v. Cuyahoga Community College Dist. (Slip Opinion), 120 N.E.3d 830

George Daher, a former part-time police dispatcher for Cuyahoga Community College, brought a civil suit alleging discrimination, retaliation, and later malicious prosecution after his indictment was dismissed and criminal records sealed.
Daher subpoenaed the Cuyahoga County court reporter for grand-jury transcripts, notes, and exhibits relating to his indictment to support his malicious-prosecution claim.
The court reporter moved to quash, citing the secrecy of grand-jury materials and the Ohio rule requiring a particularized need for disclosure outside criminal proceedings (In re Petition for Disclosure of Evidence).
The trial court held the motion in abeyance and ordered the court reporter to submit the grand-jury materials for in camera inspection.
The court reporter appealed; the Eighth District dismissed for lack of a final, appealable order. The Supreme Court accepted jurisdiction to resolve whether the in camera-order was final and appealable.
The Supreme Court held the in camera inspection order is not a final, appealable order under R.C. 2505.02(B)(4) because it neither grants nor denies the provisional remedy of disclosure.

Issue	Plaintiff's Argument (Daher)	Defendant's Argument (Court Reporter)	Held
Whether an order requiring in camera submission of grand-jury materials is a final, appealable order under R.C. 2505.02(B)(4)	Daher sought access to grand-jury materials to rebut probable-cause presumption for malicious-prosecution claim	The court reporter argued the in camera order effectively grants disclosure by sanctioning use of a civil subpoena and thus is immediately appealable	The Court held the in camera order is not final or appealable; it is a preliminary step, not the grant or denial of the provisional remedy of disclosure
Whether parties may obtain in camera inspection of grand-jury materials via civil subpoena (procedural route)	Daher used a subpoena duces tecum to seek materials during civil discovery	The court reporter argued such subpoenas circumvent the In re Petition for Disclosure framework requiring a petition and showing of particularized need	The Court did not decide this issue on the merits because it dismissed the appeal for lack of jurisdiction; it noted the question remains unresolved here

In re Petition for Disclosure of Evidence Presented to Franklin Cty. Juries in 1970, 63 Ohio St.2d 212 (Ohio 1980) (establishes particularized-need standard for disclosure of grand-jury materials)
State v. Muncie, 91 Ohio St.3d 440 (Ohio 2001) (defines the relevant order as the mandate granting or denying the relief at issue)
In re Special Grand Jury Investigation Concerning Organic Technologies, 84 Ohio St.3d 304 (Ohio 1999) (explains purposes of grand-jury secrecy)
Henneman v. Toledo, 35 Ohio St.3d 241 (Ohio 1988) (discusses in camera review as a tool for protecting confidentiality)
State ex rel. Grandview Hosp. & Med. Ctr. v. Gorman, 51 Ohio St.3d 94 (Ohio 1990) (characterizes in camera review as a minimal, first step in discovery dispute resolution)
State v. Anderson, 138 Ohio St.3d 264 (Ohio 2014) (sets test for final appealable orders under R.C. 2505.02(B)(4))