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Newsletter Distribution Lists May Not Be Public Records

In the case of Hicks v. Union Twp., 2023-Ohio-874, an appellate court held that email and mailing distribution lists for a township newsletter were not records under R.C. 149.43 as they did not document a governmental function of the township. In this case, a public record requester argued that the email and mailing lists documented […]

No Contract When a Former Member Tries to Renew Expired Membership

In the case of Redding v. United States Parachute Assn., Inc., 2023-Ohio-884, an appellate court held that a former member of the United States Parachute Association (“USPA”) may have pled sufficient facts to overcome a motion to dismiss an Ohio Whistleblower claim under R.C. 4113.52, but failed in his other cause of action because there […]

Mere Rumors of Prior Harassment Do Not Trump Timely and Appropriate School District Action in Response to Formal Harassment Complaint

In the case of Greenberg v. Toledo Pub. Schools, 2023-Ohio-864, an appellate court held that a former teacher could not prevail upon alleged hostile-work environment, sexual harassment claims against a school district as the school district took timely and appropriate action to address the harassment as soon as the school district had either actual or […]

A Failure to Provide Education in the Least Restrictive Environment Leads to IDEA Claims but not Discrimination Claims

In the case of Knox Cty. v. M.Q., 62 F.4th 978 (6th Cir.2023), a federal appellate court held that (1) the school violated the Individuals with Disabilities Education Act’s (“IDEA”) mandate that students receive their education in the least restrictive environment when the school tried to place the student in a comprehensive development classroom (“CDC-A”) […]