State ex rel. Paluch v. Zita (Slip Opinion), 22 N.E.3d 1050

In 2013 Norton voters amended the charter to require televised public airings of all council meetings via a live broadcast.
Paluch, a Norton resident, petitioned for a writ of mandamus arguing the city violated the charter by not televising meetings.
Section 3.20 requires public airings that are televised live, with repeats and available copies at low cost or free if the citizen provides recording media.
From March 1, 2013, Norton live-streamed meetings over the Internet on the city website, with recordings available upon request.
The Ninth District granted summary judgment for the city, holding the charter’s language did not specify the means of televising and that Internet streaming satisfied the requirement.
Paluch appealed, contending the term “televise” has a fixed meaning that excludes Internet streaming; the majority affirmed the trial court’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did mandamus lie to compel compliance with Section 3.20?	Paluch asserts a clear legal right to mandamus to force televising.	Zita contends the charter’s means are discretionary and mandamus cannot control discretion.	Yes, the court affirmed the denial of mandamus; the charter’s means were discretionary and compliance was found.
Does the term “televised” require traditional television, excluding Internet streaming?	Paluch argues “televise” has a fixed meaning that excludes Internet streaming.	City argues the amendment focuses on “public airings,” not the medium.	The term is fluid; Internet streaming can constitute public airings under the charter.
Did the charter’s language define “public airings” and “televised” narrowly or broadly?	Paluch contends the definitions fix the modality.	Zita and the appellate court treated the terms as accommodating newer technologies.	The majority treated the terms as flexible, allowing live Internet streaming as compliant.

State ex rel. Waters v. Spaeth, 131 Ohio St.3d 55 (Ohio 2012) (mandamus standard; clear right and duty required; adequate remedy absent)
State ex rel. Hillyer v. Tuscarawas Cty. Bd. of Commrs., 70 Ohio St.3d 94 (Ohio 1994) (abuse of discretion standard in mandamus review)
State ex rel. Breaux v. Court of Common Pleas, 50 Ohio St.2d 164 (Ohio 1977) (writ will not issue to compel completed legal duty)
Hunt v. Shoemaker, 17 Ohio St.3d 65 (Ohio 1985) (court may defer to statutory/charter interpretation when duty is satisfied)
Ohio Neighborhood Fin., Inc. v. Scott, 139 Ohio St.3d 536 (Ohio 2014) (unambiguous language and statutory interpretation principles)