State Ex Rel. Dawson v. Bloom-Carroll Local School District, 131 Ohio St. 3d 10

Dawson sought mandamus to obtain itemized law-firm invoices and insurer communications identifying Janet Cooper as district's attorney in a Dawson-related matter.
District provided invoice summaries but withheld itemized descriptions as confidential attorney-client information.
Dawson later requested insurer letter appointing Cooper and describing district/insurer liability; district identified one responsive document and declined further disclosure.
Motions and evidentiary proceedings followed, including an order for in camera review and submission of unredacted records.
District argued records are exempt under attorney-client privilege and trial-preparation; Dawson argued waiver through public disclosure.
Court ultimately held the records were exempt and denied the mandamus relief, including any fees or damages.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are itemized attorney-fee bills exempt from disclosure?	Dawson claims itemized bills are not privileged and must be disclosed.	District asserts itemized bills reveal confidential communications and are privileged.	Yes; itemized bills tied to privileged communications are exempt.
Is the February 9, 2010 insurer letter naming Cooper as district's attorney privileged?	Dawson contends the letter is a public-records item subject to disclosure.	District asserts the letter is protected by attorney-client privilege as a communications from insurer/defense counsel.	Yes; the letter is privileged as an insurer-attorney communication.
Has voluntary disclosure waived the privilege?	Dawson argues board/public disclosures waive any exemption.	District contends disclosure did not reveal contents or undermine privilege.	No; waiver not established by the disclosed board/public references.
Did the district meet its burden to prove applicability of the privilege?	Dawson asserts insufficient showing to withhold records.	District provided affidavits and evidence supporting privilege.	Yes; burden met, records properly exempt.

State ex rel. Cincinnati Enquirer v. Dupuis, 98 Ohio St.3d 126 (2002-Ohio-7041) (waiver by voluntary disclosure requires showing of content disclosure)
State ex rel. Taxpayers Coalition v. Lakewood, 86 Ohio St.3d 385 (1999) (attorney-client privilege extends to confidential records and billing narratives)
State ex rel. Toledo Blade Co. v. Toledo–Lucas Cty. Port Auth., 121 Ohio St.3d 537 (2009-Ohio-1767) (records law balanced with privilege; contents matter for disclosure)
State ex rel. Cincinnati Enquirer v. Jones-Kelley, 118 Ohio St.3d 81 (2008-Ohio-1770) (strict construction of exceptions; custodian bears burden)
Mahajan v. State Med. Bd. of Ohio, 127 Ohio St.3d 497 (2010-Ohio-5995) (public-records claims must have merit; discretionary costs)
Swidler & Berlin v. United States, 524 U.S. 399 (1998) (attorney-client privilege fosters candid communications)