State Ex Rel. Anderson v. City of Vermilion, 134 Ohio St. 3d 120

Anderson, former Vermilion mayor, requested January–April 2010 itemized attorney-billing statements for services provided to the city.
The city denied disclosure claiming the statements were exempt under the attorney-client privilege.
The statements described the matters, dates, tasks, hours, rates, and amounts billed for Stumphauzer & O'Toole and Marcie & Butler.
The court of appeals reviewed under an in camera framework and denied mandamus while sealing the statements.
The Supreme Court held that nonexempt portions must be disclosed, with the narratives redacted to protect privileged material.
Damages and attorney-fees requests were denied on the basis that most records were exempt or reasonably believed exempt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are nonexempt portions of itemized bills discloseable?	Anderson argues nonexempt data must be released.	Vermilion contends the records are exempt by attorney-client privilege.	Yes; nonexempt portions must be disclosed after redacting privileged content.
Was Anderson's mandamus claim moot after summaries were provided?	Post-judgment summaries did not moot the claim for January 2010–April 2010 records.	Providing summaries mooted the mandamus claim.	Not moot; distinction in time period means claim persists for January–April 2010 records.
May redaction render the records meaningless to the requester?	Redacting narrative details could deprive Anderson of useful information.	Redacted data still reveals hours, rates, and general matters.	Redaction consistent with statute; nonexempt data must be disclosed.
Did the court of appeals abuse its discretion on damages/fees?	Dawson and related cases support awarding damages/fees for improper withholding.	Many records were exempt; damages/fees denial was reasonable.	No abuse; damages/fees denied due to exemption and reasonable belief of exemption.

State ex rel. Physicians Commt. for Responsible Medicine v. Ohio State Univ. Bd. of Trustees, 108 Ohio St.3d 288 (2006-Ohio-903) (liberal construction in public-records act; disclosure favored)
State ex rel. Rocker v. Guernsey Cty. Sheriff’s Office, 126 Ohio St.3d 224 (2010-Ohio-3288) (resolve doubts in favor of disclosure; standards for records requests)
State ex rel. Cincinnati Enquirer v. Jones-Kelley, 118 Ohio St.3d 81 (2008-Ohio-1770) (strict construction against custodian; burden to prove exception)
State ex rel. Dawson v. Bloom-Carroll Local School Dist., 131 Ohio St.3d 10 (2011-Ohio-6009) (narrative portions privileged; nonexempt portions may be withheld)
State ex rel. McCaffrey v. Mahoning Cty. Prosecutor’s Office, 133 Ohio St.3d 139 (2012-Ohio-4246) (nonexempt portions may be disclosed when redacted; case on point for privilege scope)
Natl. Broadcasting Co., Inc. v. Cleveland, 38 Ohio St.3d 79 (1988-Ohio-526) (syllabus on public-records disclosure standards)