Jones v. Geauga Cty Republican Party Cent. Commt., 82 N.E.3d 16

Plaintiffs (Diane Jones, et al.) sued the Geauga County Republican Party Central Committee and its chair alleging an August 15, 2015 meeting was closed when it should have been open under Ohio’s Open Meetings Act (R.C. 121.22). Plaintiffs sought declaratory and injunctive relief and invalidation of actions taken at that meeting.
Plaintiffs alleged the committee removed members of the public while allowing prospective new committee appointees to remain, and failed to properly vote to go into executive session or identify subjects as required by statute.
The committee moved to dismiss under Civ.R. 12(B)(6), arguing the meeting concerned the party’s internal affairs (amending bylaws and appointing committee members) and therefore was not "public business" subject to R.C. 121.22.
The trial court granted the motion and dismissed the complaint with prejudice, ruling the Open Meetings Act did not apply to the committee’s internal proceedings.
On appeal the Eleventh District affirmed, holding the complaint failed to allege the committee was deliberating over "public business" as defined by Ohio law and precedent; appointing party committee members and amending internal bylaws are internal party affairs, not public business.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a county central committee’s meeting to amend bylaws and appoint new committee members is a "meeting" conducting "public business" under R.C. 121.22	The August 15 meeting involved voting on matters (bylaws amendment and appointments) that required openness under R.C. 121.22; actions taken there are invalid if closed	The meeting addressed internal party affairs (bylaws and committee membership); R.C. 121.22 applies only when the committee is exercising statutory public powers (e.g., filling county office vacancies under R.C. 305.02)	Held: Not public business. Allegations do not show the committee was conducting government business subject to R.C. 121.22, so complaint failed to state a claim
Availability of declaratory/injunctive relief under R.C. 2721/R.C. 121.22 based on the alleged violation	Plaintiffs sought declaratory judgment and injunction to enjoin future Open Meetings Act violations	Committee argued plaintiffs cannot obtain relief because the statute does not apply to internal party meetings as alleged	Held: Because complaint failed to allege a statutory violation, plaintiffs have no right to declaratory relief; dismissal affirmed

State ex rel. Hayes v. Jennings, 173 Ohio St. 370 (court recognized that when central committee exercises statutory power to fill vacancies it acts as public officers)
State ex rel. Cain v. Kay, 38 Ohio St.2d 15 (limiting Hayes: courts will not intrude into internal party affairs unless the committee assumes duties affecting government beyond internal sphere)
Banchy v. Republican Party of Hamilton Cty., 898 F.2d 1192 (6th Cir.) (central committee actions are state action only when performing narrow statutory duties; internal party activities are not state action absent direct influence on governmental duties)
White v. King, 147 Ohio St.3d 74 (2016) (defining "public business" as matters over which the governmental body has supervision, control, jurisdiction, or advisory power)
State ex rel. Fenske v. McGovern, 11 Ohio St.3d 129 (declaratory-judgment dismissal means plaintiff has no right to a declaration when complaint fails to state a viable claim)
State ex rel. Long v. Council of the Village of Cardington, 92 Ohio St.3d 54 (Open Meetings Act’s purpose is to require official business to be conducted in open meetings)