In the case of Miller v. Ohio Dept. of Health, Vital Statistics, 2021-Ohio-1901 the Court found that a public records request that involves creating a report from existing data does not constitute a customized dataset and is a valid request.
Here, the requesting party sought a report with the causes of death in Ohio where the reports were coded as COVID-19 being the cause. The government entity argued this information would violate R.C. 3701.17(A)(2) and that they were not required to disclose information that requires a unique database query. The Court disagreed.
The Court reasoned that if the report can be created from existing software with information that is readily available and the data is in summary, statistical, or aggregate form, it does not violate the statute and is a valid public records request.
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.