The Ohio Supreme Court issued a unanimous decision ordering the Xenia Community City School District to release email distribution lists as public records, rejecting the district's claims that the information was exempt from disclosure.
In *State ex rel. Boddy v. Xenia Community City School Dist. Bd. of Edn.* (2026-Ohio-164), the court held that email distribution lists maintained by the school district qualify as public records under Ohio Revised Code 149.011(G) because they document the district's functions and procedures. The decision was issued Jan. 22, 2026, following oral arguments submitted in October 2025.
Relator Darbi Boddy had requested access to the school district's email distribution lists through Ohio's Public Records Act. The Xenia Community City School District and its treasurer, Thomas Massie, refused to provide the requested records, prompting Boddy to file an original mandamus action with the state's highest court.
The case centered on whether email distribution lists created and maintained by public school districts constitute public records subject to disclosure. Under Ohio law, public records are defined as records kept by public offices that document their organization, functions, policies, decisions, procedures, operations, or other activities.
The court's per curiam opinion, joined by Chief Justice Kennedy and Justices DeWine, Brunner, Deters, Hawkins, and Shanahan, concluded that the email lists clearly fall within this definition. Justice Fischer concurred with the ruling but disagreed with awarding statutory damages to the requestor.
The school district had argued that the email distribution lists qualified for exemption under state or federal law, which would have shielded them from mandatory disclosure. However, the court found that the district failed to meet its burden of proving the lists fell squarely within any recognized exemption from Ohio's Public Records Act disclosure requirements.
This ruling builds on established Ohio precedent regarding what constitutes a public record while distinguishing previous decisions. The court specifically noted that its decision differed from *State ex rel. Dispatch Printing Co. v. Johnson*, though the opinion excerpt does not detail the specific distinctions drawn.
The decision carries significant implications for transparency in public education. Email distribution lists often contain contact information for parents, students, staff, and community members who receive communications from school districts. The ruling suggests that such operational tools used by public entities cannot be automatically shielded from public scrutiny simply because they contain contact information.
For school districts across Ohio, this decision clarifies that digital communication tools and databases used in their operations are subject to the same transparency requirements as traditional paper records. Districts must now carefully evaluate their policies regarding email distribution systems and other digital records management practices.
The court not only granted the writ of mandamus compelling disclosure but also awarded Boddy significant relief under Ohio's Public Records Act. The requestor received court costs, reasonable attorney fees, and $1,000 in statutory damages. These monetary awards serve as both compensation for the litigation expenses incurred and a deterrent against frivolous denials of public records requests.
Statutory damages under Ohio's Public Records Act are available when public offices fail to comply with disclosure requirements without reasonable justification. The award of such damages in this case suggests the court found the school district's refusal to release the email lists lacked adequate legal foundation.
The case represents the latest development in ongoing tensions between government transparency and privacy concerns in the digital age. While public records laws aim to ensure government accountability, public entities often argue that certain digital information should remain confidential to protect individual privacy or operational security.
The Ohio Supreme Court's decision provides clear guidance that email distribution lists created by public school districts to facilitate their communication functions are not exempt from disclosure simply because they contain contact information. This ruling may influence how other public entities across Ohio handle similar requests for digital records.
For requestors seeking public records from Ohio school districts and other public entities, this decision strengthens their ability to access information about how these organizations operate and communicate with stakeholders. It reinforces that Ohio's Public Records Act applies broadly to modern digital records and communication systems.
The unanimous nature of the decision, with only Justice Fischer's partial dissent regarding damages, suggests strong consensus on the court about the scope of Ohio's public records law in the digital context. This clarity should help both public entities and records requestors understand their respective rights and obligations moving forward.