State ex rel. Schiffbauer v. Banaszak, 33 N.E.3d 52

Relator Schiffbauer, a campus news editor, sought Otterbein University police records documenting criminal reports.
Otterbein police are sworn, state-certified officers with plenary police power.
Campus police at private universities are created under R.C. 1713.50(B) and must be trained by POTC.
Campus officers have powers equal to municipal or county officers, but mainly on university property.
Court held the Otterbein police department is a public office under R.C. 149.011(A) and must produce records.
Dissenting opinions object to treating private university police as public offices; writ issued by majority.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is Otterbein police a public office under the Public Records Act?	Schiffbauer: department performs a government function and is a public office.	Otterbein: private university, not established by state law as a public office.	Yes; it is a public office; writ granted.

State ex rel. Freedom Communications, Inc. v. Elida Community Fire Co., 82 Ohio St.3d 578 (1998) (private nonprofit can be a public office when performing a government function)
State ex rel. Toledo Blade Co. v. Univ. of Toledo Found., 65 Ohio St.3d 258 (1992) (private entities may be public offices when performing government functions)
State ex rel. Oriana House, Inc. v. Montgomery, 110 Ohio St.3d 456 (2006) (functional-equivalency test not applicable here)
State ex rel. Lee v. Karnes, 103 Ohio St.3d 559 (2004) (presume legislature means what it says; avoid rewriting statute)