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Correctional Institution Shift Rosters Constitute Security Records

In the case of State ex rel. Burfitt v. Sehlmeyer, Slip Opinion No. 2020-Ohio-5147, the Ohio Supreme Court held that correctional institution shift rosters constituted security records exempt from public disclosure because such rosters contained information on officer assignments, officer firearm certifications, and emergency response plans.

In this case, a prison inmate made a public records request seeking the disclosure of correctional institution shift rosters. In rejecting the public records request, the correctional institution argued that the shift rosters in question were protected under R.C. 149.433(A) as “security records.” In agreeing with the correctional institution, the Ohio Supreme Court concluded that the shift rosters were not public records as they contained “information directly used for protecting or maintaining the security of a public office against attack, interference, or sabotage” and left the correctional institution vulnerable to attack. R.C. 149.433(A)(1).

To read this case, click here.

Authors: Matthew John Markling and the McGown & Markling Team.

Note: This blog entry does not constitute – nor does it contain – legal advice. Legal jurisprudence is like the always-changing Midwestern weather. As a result, this single blog entry cannot substitute for consultation with a McGown & Markling attorney. If legal advice is needed with respect to a specific factual situation, please feel free to contact a McGown & Markling attorney.

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