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Library Meeting Room Records Constitute Library Records and Patron Information

In the case of Mentch v. Cleveland Hts. Univ. Hts. Library, 2020-Ohio-5162, it was concluded that scheduling, payment, and usage records for a library meeting room may not be disclosed as such records constitute both library records and patron information.

In this case, an individual made a public records request for scheduling, payment, and usage records for a library meeting room. In rejecting the public records request, the library argued that the records were protected as both a “library record” and “patron information.” The special master agreed with the library.

The library meeting room records were found to be “library records” because the records contained “[i]nformation that the library requires an individual to provide in order to be eligible to use library services or borrow materials” and constituted the use of a library service. R.C. 149.432(A)(2)(a).

The library meeting room records were found to be “patron information” because the records contained “personally identifiable information about an individual who has used any library service or borrowed any library materials” regardless of whether the individual was a library cardholder. R.C. 149.432(A)(3).

To read the special master’s recommendation and report, click here.

To read the Court of Claim’s order adopting the special master’s recommendation and report, 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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