Paridon v. Trumbull Cty. Children Servs. Bd.
2013 Ohio 881
Ohio Ct. App.2013Background
- Paridon v. Trumbull County Children Services Bd.; Ohio Eleventh Appellate Dist. before Rice, J.
- Plaintiffs sought injunction to stop sign-in requirement for board public meetings under R.C. 121.22 (Sunshine Law).
- Board policy requires sign-in and identity disclosure to enter its facility for meetings; policy applies day and evening; no verification or background checks on sign-ins.
- Meeting Oct. 18, 2011 held in gym at board facility; residents and confidential records exist there; access routes from multiple areas.
- Trial court denied injunction, finding sign-in policy non-violation of Sunshine Law and narrowly tailored for security; Appellants appeal.
- Grendell, J., dissents indicating sign-in violation of Sunshine Law; majority affirms trial court’s ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether sign-in policy violates Sunshine Law open-meeting requirements | Paridon argues sign-in unlawfully conditions access | Board contends sign-in is a content-neutral, narrowly tailored security measure | No violation; policy permitted as time/place/manner restriction |
Key Cases Cited
- Dayton v. Esrati, 125 Ohio App.3d 60 (2d Dist.1997) (permissible content-neutral access restrictions in open meetings)
- Specht v. Finnegan, 149 Ohio App.3d 201 (6th Dist.2002) (open meetings may be subject to reasonable access controls)
- Randles v. Hill, 66 Ohio St.3d 32 (1993) (Sunshine Law openness; restrictions must not preclude access)
- Holeski v. Lawrence, 85 Ohio App.3d 824 (11th Dist.1993) (clear and convincing standard for injunctions in Sunshine Law cases)
- Fayette Volunteer Fire Dept. No. 2, Inc. v. Fayette Twp. Bd. of Twp. Trustees, 87 Ohio App.3d 51 (4th Dist.1993) (injunction standard; open meetings with non-disruptive restrictions)