Definition of Public Records Shifts
State ex rel. Cincinnati Enquirer v. Ronan,
Slip Opinion No. 2010-Ohio-5680
A contrary conclusion would lead to the
absurd result that any document received by a public office and retained by that
office would be subject to R.C. 149.43 regardless of whether the public office
ever used it to perform a public function. The plain language of R.C. 149.011(G),
which requires more than mere receipt and possession of a document in order for
it to be a record for purposes of R.C. 149.43, prohibits this result.” (Emphasis
sic.) Id. at 64