Narrative Opinion Summary
The case involves a dispute over access to Miami University Disciplinary Board records from 1993-1996, with relators seeking these records under the Ohio Public Records Act. The respondents argued the records were exempt from disclosure under R.C. 149.43(A)(1), claiming protection under the Family Educational Rights and Privacy Act (FERPA). However, the court determined that these disciplinary records do not qualify as 'education records' under FERPA, as they do not relate to academic performance or financial aid. Citing precedent, the court explained that while FERPA penalizes improper disclosure, it does not outright prohibit it. The court ruled in favor of the relators, granting a writ of mandamus to compel the release of the records, provided personal information is redacted. The decision underscores the statutory mandate for open government and the strict construction of exceptions against the custodian. The court awarded attorney fees and costs to the relators and did not address additional arguments concerning other statutory exceptions. The ruling emphasizes transparency in university disciplinary proceedings as fundamental for ensuring campus safety and providing vital information to prospective students and their families.
Legal Issues Addressed
Access to Governmental Records under Ohio Public Records Actsubscribe to see similar legal issues
Application: The court determined that records of Miami University Disciplinary Board proceedings are subject to disclosure under the Ohio Public Records Act, as they do not fall within the exceptions outlined in the Act.
Reasoning: The Ohio Public Records Act mandates broad access to governmental records unless a specific exception applies.
Definition of Education Records under FERPAsubscribe to see similar legal issues
Application: The court found that disciplinary records from Miami University are not classified as 'education records' under FERPA, as they do not concern academic performance or financial aid.
Reasoning: Relators countered that FERPA does not apply, as the records in question do not pertain to academic performance or financial aid but rather to disciplinary matters.
FERPA's Impact on Disclosuresubscribe to see similar legal issues
Application: The court clarified that while FERPA penalizes institutions for improper disclosure of education records, it does not constitute an outright prohibition against releasing such records.
Reasoning: Citing Red Black Publishing Co. v. Bd. of Regents of Univ. Sys. of Georgia, the court highlighted that FERPA penalizes institutions for improper disclosure but does not outright prohibit it.
Mandamus to Compel Record Disclosuresubscribe to see similar legal issues
Application: A writ of mandamus was granted to compel the release of disciplinary records with personal information redacted, affirming the public's right to access such records.
Reasoning: Consequently, the court ruled in favor of the relators, granting a writ of mandamus for the release of the requested records, provided personal information about students is redacted.
Strict Construction of Public Record Exceptionssubscribe to see similar legal issues
Application: The court emphasized that exceptions to public record disclosure under Ohio law must be strictly construed against the custodian, favoring public access in case of doubt.
Reasoning: Inherent in R.C. 149.43 is the principle of promoting open government, which mandates that exceptions to public record disclosure be strictly construed against the custodian.