State ex rel. Bell v. Brooks

Appellant Greg Bell requested that County Risk Sharing Authority (CORSA), a joint self-insurance pool whose members included the majority of Ohio's counties, provide him with certain CORSA records pursuant to Ohio Rev. Code 149.43 and Ohio Rev. Code 149.431. David Brooks, the managing director of property and casualty insurance for CORSA, refused to provide copies of the records, asserting that they were not public records and that CORSA was a private corporation and not a public office subject to section 149.43. Bell filed for writs of mandamus to compel Brooks to provide copies of the requested CORSA records. The court of appeals denied the requested writs. The Supreme Court (1) affirmed the judgment of the court of appeals insofar as it denied the writs relating to Bell's claim for CORSA's board meeting minutes on grounds that CORSA was not the functional equivalent of a public office for purposes of section 149.43, but (2) reversed to the extent that the court of appeals failed to consider Bell's records requests for CORSA's financial and compensation records as CORSA's status as a private, nonprofit corporation was not dispositive in regard to these claims. Remanded.