Medina County Prosecutor's
Casual Opinion of Our Stored Email Addresses
It is the opinion of this Office
(Prosecutor's Office) that the requested personal e-mail addresses of private
citizens are not public records and need not be provided.
Public records are records that
include "any document ***, created or received by or coming under the
jurisdiction of any public office ***, which serves to document the
organization, functions, policies, decisions, procedures, operations, -or other
activities of the office." R.C. 149.011 (A). An item that does not serve to so
document the activities of a public office is not a public record and need not
The disclosure of personal e-mail
addresses of private citizens requesting information of a governmental office
"does little to ensure the accountability of government or shed light on
***[its] performance of its statutory duties." State ex rel Beacon Journal v.
Bond (2002), 98 Ohio St. 3d 146,149 [PI 1]. The Supreme Court of Ohio has
determined that the disclosure of information about private citizens is not
required when such information "reveals little or nothing about an agency's own
conduct and would do nothing to further the purposes of the Public Records Act."
State ex rel McCleary v. Roberts (2000), 88 Ohio St. 3d 365 at 368 and 369.
It is the position of this Office,
under the guidelines set by the Supreme Court of Ohio, that the personal e-mail
addresses of private individuals, which are voluntarily submitted to the County
Auditor solely for the administrative purpose of providing a contact address for
individuals who have requested that they be provided certain information
updates, are not public records and need not be disclosed. The personal e-mail
addresses of these private individuals reveal little or nothing about the County
Auditor's conduct of his operations or statutory duties; unauthorized disclosure
would compromise privacy interests and does nothing to further the purposes of
the Public Records Act.