State ex rel. Miller v. Pinkney (Slip Opinion), 2017 Ohio 1335

Relator Mark W. Miller requested all offense/incident reports in the Cuyahoga County Sheriff’s Office identifying Edward FitzGerald as reportee, complainant, or victim under Ohio’s Public Records Act (R.C. 149.43).
Sheriff’s public-records manager Judy Blatnik denied the request, claiming the records were "security records" exempt from disclosure under R.C. 149.433.
The Ohio Supreme Court ordered the sheriff to submit all responsive reports to the Court under seal for in camera review to determine which, if any, qualified as security records.
The Court examined the submitted incident/offense reports dated between May 2012 and August 2014.
The Court determined those identified routine incident reports are not security records and are subject to release with redaction of exempt information.
The writ of mandamus was therefore granted in part (release with redactions) and denied in part (to the extent respondent had claimed blanket exemption); costs and reasonable attorney fees were awarded and to be calculated later.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether routine incident/offense reports identifying FitzGerald are public records	Miller: Reports are routine incident reports and normally subject to immediate release under the Public Records Act	Sheriff: Reports are "security records" under R.C. 149.433 and thus exempt from mandatory disclosure	Court: Reports examined are not security records; subject to release with redaction of exempt material
Whether in camera review was appropriate to determine status of records	Miller: Implicitly supported in order for judicial determination	Sheriff: Opposed to disclosure and asserted statutory exemption without conceding need for in camera review	Court: Ordered and conducted in camera review to resolve statutory exemption claim
Scope of redaction permitted when releasing reports	Miller: Requested production of responsive reports (with redactions as required)	Sheriff: Sought to withhold entire reports as security records	Court: Allowed release of reports but required redaction of exempt information rather than wholesale withholding
Entitlement to fees and costs on mandamus action	Miller: Sought costs and reasonable attorney fees	Sheriff: No specific counterpoint in opinion summary	Court: Awarded costs and reasonable attorney fees; amount to be determined upon itemized application

State ex rel. Beacon Journal Publishing Co. v. Maurer, 91 Ohio St.3d 54 (recognizing incident reports initiate investigations and are normally public)
State ex rel. Lanham v. Smith, 112 Ohio St.3d 527 (routine offense and incident reports are normally subject to immediate release)
State ex rel. Miller v. Bova, 147 Ohio St.3d 1456 (Court ordered in camera submission of responsive records to determine applicability of security-record exemption)