Miller v. OH St. Hwy. Patrol
Annotate this CaseMiller filed a mandamus action, alleging that he sent a public-records request to the Ohio State Highway Patrol on September 9, 2011, seeking records relating to traffic incidents involving a particular trooper. The agency provided some records, but Miller claims that it withheld video and audio recordings and reports concerning the traffic stop and arrest of a particular person on July 15 or 16, 2011. The agency asserted the investigatory-work-product exception to the Public Records Act, R.C. 149.43. The court found that Miller’s evidence had not been presented in a timely manner or in the required form, which mandates dismissal by local rule, but considered the evidence, which included a letter from the Highway Patrol establishing on its face that it refused to release certain documents requested by Miller. The court then dismissed for noncompliance with the rules. The Ohio Supreme Court remanded, holding that the Highway Patrol must support its contention that the withheld material falls under the “confidential law enforcement investigatory record” exception to the Public Records Act.
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