State ex rel. Louisville Edn. Assn., OEA/NEA v. Louisville City School Dist. Bd. of Edn.
2017 Ohio 5564
Ohio Ct. App.2017Background
- Relator Louisville Education Association requested public records from Louisville City School District, including all administrative W-2s for fiscal years 2013–2015.
- Respondent produced the W-2s but redacted portions showing tax-sheltered account deductions, charitable contributions, and amounts of taxes withheld.
- Respondent explained the redactions were made because the redacted information was not public.
- Relator filed an action seeking a writ of mandamus to compel disclosure under Ohio’s Public Records Act, R.C. 149.43.
- The parties submitted briefs and argued the matter to the Fifth District Court of Appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether deductions and tax-withholding data on employee W-2s are public records subject to disclosure under R.C. 149.43 | The W-2s are public records and the redacted payroll-related data must be disclosed | The payroll deductions, charitable contributions, and tax withholding amounts are non-public personal information properly redacted | The court held the redacted information is not public because it does not document agency organization or function and may be redacted after review |
Key Cases Cited
- State ex rel. Physicians Commt. for Responsible Medicine v. Ohio State Univ. Bd. of Trustees, 108 Ohio St.3d 288 (2006) (mandamus is the appropriate remedy to enforce Ohio’s Public Records Act)
- State ex rel. McCaffrey v. Mahoning Cty. Prosecutor's Office, 133 Ohio St.3d 139 (2012) (relator must prove entitlement to mandamus by clear and convincing evidence)
- State ex rel. Data Trace Information Servs., L.L.C. v. Cuyahoga Cty. Fiscal Officer, 131 Ohio St.3d 255 (2012) (public-records relators need not show lack of an adequate remedy in the ordinary course of law)
- State ex rel. Cincinnati Enquirer v. Deters, 148 Ohio St.3d 595 (2016) (discussing standards for public-records mandamus actions)
- Morgan v. State, 121 Ohio St.3d 600 (2009) (Public Records Act contemplates pre-release legal review to redact exempt materials)
- State ex rel. Warren Newspapers, Inc. v. Hutson, 70 Ohio St.3d 619 (1994) (recognizes office may examine records to redact exempt information)
- State ex rel. Davis v. Metzger, 139 Ohio St.3d 423 (2014) (personnel files require careful redaction of sensitive employee information that does not document agency function)