Public access laws in your state

< previous | Alabama - Kentucky | Louisiana - Ohio | Oklahoma - Wyoming | next >

Here's what state public records and open meetings laws say about access to nongovernmental bodies. These short descriptions are taken from the 2006 edition of the Open Goverment Guide, the Reporters Committee's guide to navigating public access laws. Each entry is prepared by open government experts in that state; to see their names, click the "See full OGG entry" link at the end of each state's entry.

Louisiana
Bodies receiving public funds or benefits: Nongovernmental bodies receiving public funds are subject to the statute, to the extent that the records pertain to the receipt of public funds. See La. Rev. Stat. Ann. § 17:3390 (nonprofit corporations that support public colleges and universities); Guste v. Nicholls College Foundation, 564 So. 2d 682 (La. 1990) (records of nonprofit corporation organized to support public university are public to the extent records relate to receipt and expenditure of mandatory student dues paid initially by university to alumni association, but nevertheless constituting public funds); Lewis v. Spurney, 456 So. 2d 206 (La. App. 4th Cir. 1984), writ denied, 457 So. 2d 1183 (La. 1984), writ denied, 458 So. 2d 488 (La. 1984) (financial records of the Louisiana World Exposition, a private nonprofit corporation which created and operated the 1984 World's Fair, are public records insofar as those records date from the time LWE received state funds); Carter v. Fench, 322 So. 2d 305 (La. App. 1st Cir. 1975), writ denied, 325 So. 2d 277 (La. 1976) (records of public university student government association budget are public records; once tuition fees are collected by the university these fees become public funds, and those agencies which are the ultimate recipients of such funds are subject to the Public Records Act insofar as their financial records are concerned); but see Op. Att'y Gen. 93-214 (other records of student government association generally not subject to Public Records Act); and Dorson v. State of Louisiana, 657 So. 2d 755 (La. App. 4th Cir.), writ denied, 662 So. 2d 472 (La. 1995) (federally funded and authorized committees within state university system not subject to Public Records Act).

Bodies whose members include governmental officials: Such a group is covered if it receives public funds as its primary source of income, performs a public service, and renders a public function. Op. Att'y Gen. 78-282 (associations of public officials such as the Louisiana School Board Association, the Louisiana Municipal Association, and the Louisiana Police Jury Association are covered by Public Records Act). See also Op. Att'y Gen. 93-53 (Personnel board composed of Mayor and Selectmen of parish is subject to Public Records Act). But see La. Rev. Stat. Ann. § 17:3390, which, as to public college and university support foundations, would appear to limit disclosure to records of receipt and expenditure of public funds regardless of extent of public funding or public functions performed. The statute provides for the same limited records disclosure even if public university board members and employees serve on the foundation board, as long as they do not constitute a majority of the voting members. Id. See full OGG entry for Louisiana

Maine
Bodies receiving public funds or benefits: Whether a nongovernmental body is receiving public funds or benefits is a factor to be weighed in considering whether it is subject to public disclosure laws. See Town of Burlington v. Hospital Administrative District No. 1, 2001 ME 59, ¶¶ 16-19, 769 A.2d 857.

Bodies whose members include governmental officials: Whether a nongovernmental body includes governmental officials is a factor to be weighed in considering whether it is subject to public disclosure laws. Town of Burlington v. Hospital Administrative District No. 1, 2001 ME 59, ¶¶ 16-19, 769 A.2d 857 See full OGG entry for Maine

Maryland
Nongovernmental bodies: The PIA generally applies. In addition, a non-governmental body created by statute, but that receives no public funds may be subject to the PIA if: (1) the body serves a public purpose, (2) the government exercises a certain degree of control over it; and (3) it is immune from tort liability. A.S. Abell Publishing Co. v. Mezzanote, 297 Md. 26, 464 A.2d 1068 (1983) (holding that the Maryland Insurance Guaranty Association, a public entity created by statute but receiving no public funds, is subject to the PIA). See full OGG entry for Maryland

Massachusetts
Bodies receiving public funds or benefits:They are not covered by the general public records statute, and receipt of public funds does not normally make otherwise private institutions public. See Bello v. South Shore Hospital, 384 Mass. 770, 775, 429 N.E.2d 1011 (1981).

Bodies whose members include governmental officials: The records of such groups are probably not covered. The basic test is whether or not the board, committee or other group is itself governmentally appointed, and not whether some of its members may otherwise be government officials. See full OGG entry for Massachusetts

Michigan
Nongovernmental bodies:The definition of "public body" includes "[a]ny other body which is created by state or local authority or which is primarily funded by or through state or local authority." MCLA § 15.232(d)(iv); see Detroit News v. Policemen and Firemen Retirement System, 252 Mich. App. 59, 651 N.W.2d 127 (2002) (municipally chartered retirement system a public body subject to FOIA). One example of a body which has been held to be included in this definition is the President's Council of State Colleges and Universities, which is wholly funded by state universities and colleges. 1979-80 Op. Att'y Gen. 255, 262 (1979); but see Kubick v. Child and Family Services of Michigan Inc., 171 Mich. App. 304, 429 N.W. 2d 881 (1988) (government funding that amounts to less than half the total funding of a corporation does not amount to primary funding and such entity is not a public body for FOIA purposes). Also included is a state-funded university, such as the University of Michigan. Booth Newspapers Inc. v. University of Michigan Board of Regents, supra, 507 N.W.2d at 431. But see MCLA § 15.243(x) (exemption for documents concerning certain universities' presidential searches). A public body under the FOIA also includes any body that is "primarily funded" by or through state or local authority. Jackson v. Eastern Michigan University Foundation, 215 Mich. App. 240, 544 N.W. 2d 737 (1996). This is true regardless of whether the funding comes from one source or several. Scalfani v. Domestic Violence Escape, 255 Mich. App. 683, 660 N.W.2d 97 (2003) (legislative use of the word "authority" in the statute embraces the plural form as well). The term "funded" has been held not to include public monies paid in exchange for goods provided or services rendered. Breighner v. Michigan High School Athletic Ass'n, 471 Mich. 217, 683 N.W.2d 639 (2004) (private, nonprofit association of state high schools financed in part by public monies in exchange for scheduling and event hosting services not a public body subject to FOIA); see also State Defender Union Employees v. Legal Aid and Defender Ass'n of Detroit, 230 Mich. App. 426, 584 N.W. 2d 359 (1998) (private, nonprofit corporation established to provide legal services to indigent persons not a public body subject to FOIA). See full OGG entry for Michigan

Minnesota
Bodies receiving public funds or benefits: Only governmental bodies are subject to the Data Practices Act. Those entities governed by the Data Practices Act are all "state agencies, political subdivisions and statewide systems." § 13.01, subd. 1. State agencies are defined as "the state, the University of Minnesota, and any office, officer, department, division, bureau, board, commission, authority, district or agency of the state." A "political subdivision" is "any county, statutory or home rule charter city, school district, special district and any board, commission, district or authority created pursuant to law, local ordinance or charter provision." § 13.02, subd. 11.

In addition to the above, political subdivisions also include nonprofit community action agencies or a nonprofit social service agency that performs services for a governmental entity under contract.

The MGDPA was recently amended to require a government entity that contracts with a "private person" to perform any of its work to note in the contract that the government data generated by the private person are subject to the requirements of the MGDPA. § 13.05, subd. 11.

Finally, a "statewide system" is defined as "any record keeping system in which government data is collected, stored, disseminated and used by means of a system common to one or more state agencies or more than one of its political subdivisions." The Act does not define an agency subject to its provisions by the fact that it receives public funds or benefits.

Bodies whose members include governmental officials: The Act does not define entities that are subject to it by their membership. See full OGG entry for Minnesota

Mississippi
Bodies receiving public funds or benefits: These are not covered. Coverage is restricted to an "entity created by the Constitution, or by law, executive order, ordinance or resolution." § 25-61-3(a). Private non-profit corporations and limited liability corporations do not meet the definition of "public body" under the act. Att'y Gen. February 4, 2000 to Williamson.

Bodies whose members include governmental officials: These are not covered, see § 25-61-3(a). Records officials use in the performance of business for a public body are, however, covered. § 25-61-3(b). See full OGG entry for Mississippi

Missouri
Bodies receiving public funds or benefits: The Sunshine Law by its terms extends only to "public governmental bodies" -- Mo.Rev.Stat. § 610.010(4) -- and "quasi-public governmental bodies" -- Mo.Rev.Stat. § 610.010(4)(f). Entities, such as charitable groups, that are not an arm of state government or are not an arm of a government that derives its power from the state and do not meet the criteria of a quasi-public governmental body are not subject to the Sunshine Law simply because they receive state support.

Bodies whose members include governmental officials: See (a), above. Non-governmental entities are not covered by the Sunshine Law simply by virtue of the fact that governmental officials advise them or sit on their boards unless they meet the criteria outlined in Mo.Rev.Stat. § 610.010(4). See full OGG entry for Missouri

Montana
Nongovernmental bodies: The Public Records Act is silent as to whether these groups' records are open. See Mont. Code Ann. § 2-6-101(2)(a). However, the state constitution guarantees public access to the records of "public bodies" defined under the open meetings law as bodies "or organizations or agencies supported in whole or in part by public funds," Mont. Code Ann. § 2-3-203(1), and the Supreme Court used definitions found in the Montana Procurement Act to conclude that an advisory committee of the Department of Corrections was subject to the constitutional right to know in Great Falls Tribune Co. Inc. v. Day, 289 Mont 155, 959 P.2d 508 (1998). Thus, a requesting party should argue that these entities are covered by the Public Records Act, particularly if they receive public funds. See also Bryan v. Yellowstone Co. Elem. Sch. Dist. No. 2, 312 Mont. 257, 60 P.3d 381 (2002) (Montana Supreme Court held that a committee created by a school district to research a proposition and submit a recommendation to the school board was a public or governmental body subject to the right to know provision of the Montana Constitution and held the documents submitted by the committee were public documents subject to disclosure). See full OGG entry for Montana

Nebraska
Bodies receiving public funds or benefits: Records of "tax-supported districts" that are not counties, cities, villages or political subdivisions are public records. Neb. Rev. Stat. § 84-712.01(1) (Reissue 1999).

Bodies whose members include governmental officials: Not addressed by statutes. To the extent the group contains a quorum of a public body and group reviews documents, those documents are probably public records pursuant to Neb. Rev. Stat. § 84-1412(8) (Cum.Supp. 2004). See full OGG entry for Nebraska

Nevada
Bodies receiving public funds or benefits: The Act applies to educational foundations, university foundations and quasi-municipal corporations. Although the term "quasi-municipal corporation" is not defined, it may be included in the Act as "a political subdivision of the state" or "other unit of government." See N.R.S. 239.005.

Bodies whose members include governmental officials: The Act applies to educational foundations, university foundations and quasi-municipal corporations. Although the term "quasi-municipal corporation" is not defined, it may be included in the Act as "a political subdivision of the state" or "other unit of government." See N.R.S. 239.005. See full OGG entry for Nevada

New Hampshire
Whose records are and are not subject to the act? The Statute begins by defining "public proceedings" by reference to the activities of certain enumerated bodies. RSA 91-A:1-a. It then sets forth rules governing access to the meetings of "a public body, as provided in RSA 91-A:1-a." RSA 91-A:2. Public bodies are those bodies whose activities constitute the "public proceedings" as set forth in section 1-a. In section 4, the statute confers upon citizens the right to inspect "all public records" of "all such bodies and agencies," referring to the state and local bodies enumerated in section 1-a. Case law has made clear that the law applies to a wide spectrum of "bodies and agencies." Lodge v. Knowlton, 118 N.H. 574, 576 (1978) ("[W]ith the exception of the department of employment security, all State executive branch agencies and departments were meant to be and are included within the provisions of RSA 91-A"); see 1975 N.H.H.R. Jour. 600; Exec. Order 74-1 (statute applies to "each department, agency, board and commission within the state").

Specific Bodies Subject to the Statute. The statute contemplates within the term "public records" in RSA 91-A:4, the records of the following:

· The General Court (legislature), including executive sessions of committees. RSA 91-A:1-a,I(a).

· The Governor's Council and the Governor with the Governor's Council. Note that aside from meetings with the Governor's Council, the Governor is not specifically listed under the "public proceedings" section, and the Attorney General takes the position that the Statute does not apply to records in the Governor's Office. Nevertheless, such records may be sought under Part 1, Article 8 of the New Hampshire Constitution. The Supreme Court has held that agency budget requests and income estimates submitted to the Governor are within the scope of the law. Chambers v. Gregg, 135 N.H. 478 (1992).

· Boards and commissions of state, county or municipal agencies or authorities, including the Board of Trustees of the University System of New Hampshire. RSA 91-A:1-a, I(c)-(d).

· Advisory committees established by any of the foregoing public bodies.

· State executive branch agencies and departments. Union Leader Corp. v. N.H. Housing Fin. Auth., 142 N.H. 540 (1997); Lodge v. Knowlton, 118 N.H. 574 (1978). Boards or commissions created by statute but not denominated as State agencies are included.

· Nonprofit corporation formed by an association of governmental entities to provide health insurance benefits for public employees. Professional Firefighters of N.H. v. Healthtrust Inc., 151 N.H. 501 (2004).

· Office of the Legislative Budget Assistant. Goode v. N.H. Legislative Budget Assistant, 148 N.H. 551 (2002).

· Committees of state boards, commissions, councils, and the General Court. Bradbury v. Shaw, 116 N.H. 388 (1976). Note that it is not necessary that a board or committee be formally established by statute or ordinance for it to fall within the provisions of the law. Id. An "industrial advisory committee" established by a town mayor without statutory authority, consisting of local businessmen, which advised the mayor informally on development issues, solicited businesses to locate in the town, and negotiated sale of city-owned land, was held within the scope of law because of its "involvement in governmental programs." Id. at 390.

· A municipal finance committee, which has power only to make recommendations to a city council. Selkowe v. Bean, 109 N.H. 247 (1968).

Specific Bodies Not Subject to the Statute. The following are not subject to the statute:

· Department of Employment Security: RSA 91-A:6 specifically excludes from disclosure records maintained by the department under RSA 282-A:117-23.

· Courts: The Statute nowhere defines courts as public bodies, nor imposes upon courts any requirements of disclosure. Access to court records is provided by Part I, Articles 8 and 22 of the New Hampshire Constitution as interpreted by judicial decisions. The Associated Press v. State, 888 A.2d 1236 (2005), and cases cited. See full OGG entry for New Hampshire

New Jersey
Nongovernmental bodies: OPRA only applies to records of any officer, commission, agency or authority of the State or of any political subdivision thereof, including subordinate boards thereof. (See N.J.S.A. 47:1A-1.1). Consequently, records of non-governmental bodies are not subject to the law. For purposes of OPRA, Rutgers University is a public body, although attorney billing records kept by Rutgers University are not public records. However, access to some Rutgers attorney billing records may be available under common law. See Keddie v. Rutgers, 148 N.J. 36, 689 A. 2d 702 (1997); Fine v. Rutgers, 163 N.J. 464, 750 A.2d 68 (2000). See full OGG entry for New Jersey

New Mexico
Bodies receiving public funds or benefits: Undecided. However, the definition of public body contained in the Inspection of Public Records provides that all advisory boards, commissions, committees, agencies or entities created by the Constitution or any branch of government that receives any public funding are subject to the Act. § 14-2-6(D), NMSA 1978.

Bodies whose members include governmental officials: Undecided; depends upon the "body." The definition of public body contained in the Inspection of Public Records provides that all advisory boards, commissions, committees, agencies or entities created by the Constitution or any branch of government that receives any public funding are subject to the Act. § 14-2-6(D), NMSA 1978. See full OGG entry for New Mexico

New York
Bodies receiving public funds or benefits: Nongovernmental bodies which act on behalf of governmental bodies or which perform an essential public service are subject to FOIL. Perez v. City Univ. of New York, 5 N.Y.3d 522, 806 N.Y.S.2d 460(2005) (voting by student Senate of public university may not be done by secret ballot because it would prevent compilation of requisite record of final vote of each member subject to disclosure under FOIL); Westchester Rockland Newspapers v. Kimball, 50 N.Y.2d 575, 408 N.E.2d 904, 430 N.Y.S.2d 574 (1980) (granting access to records of a village volunteer fire department as performing essential public service). See Buffalo News v. Buffalo Enterprise Development Corporation, 173 A.D.2d 43, 578 N.Y.S.2d 945 (4th Dep't 1991), aff'd, 84 N.Y.2d 488, 644 N.E.2d 277, 619 N.Y.S.2d 695 (non-profit city economic development corporation acting as city's agent was government agency subject to FOIL); Russo v. Nassau Community College, 81 N.Y.2d 690, 623 N.E.2d 15, 603 N.Y.S.2d 294 (1993) (community college is an "agency" subject to FOIL and teaching materials come within law's definition of "record"); Eisenberg v. Goldstein, No. 21381-87 (Sup. Ct., Kings County, Feb. 26, 1988) (granting access to records of college not-for-profit foundation); S. W. Pitts v. Capital Newspapers, No. 8400-87 (Sup. Ct., Albany County, Jan. 25, 1988) (granting access to records of volunteer fire companies serving fire protection districts); Decker v. Ardler, No. 6986/81 (Sup. Ct., Orange County, Aug. 31, 1982).

Bodies whose members include governmental officials: Nongovernmental bodies which act on behalf of governmental bodies or which perform an essential public service are subject to FOIL. See Buffalo News v. Buffalo Enterprise Development Corporation, 173 A.D.2d 43, 578 N.Y.S.2d 945 (4th Dep't 1991), aff'd 84 N.Y.2d 488, 644 N.E.2d 277, 619 N.Y.S.2d 695 (1994) (non-profit city economic development corporation acting as city's agent was government agency subject to FOIL). Russo v. Nassau Community College, 81 N.Y.2d 690, 623 N.E.2d 15, 603 N.Y.S.2d 294 (community college was an "agency" subject to FOIL and teaching materials came within law's definition of "record"). Although not directly addressed by FOIL, records of nongovernmental groups are accessible if kept, held or filed with an agency. Capital Newspapers Division of Hearst Corporation v. Whalen, 69 N.Y.2d 246, 505 N.E.2d 932, 513 N.Y.S.2d 367 (1987) (granting access to ex-mayor's personal and political papers, when held by an agency). See full OGG entry for New York

North Carolina
Bodies receiving public funds or benefits: The North Carolina Public Records Law covers records relating to "the transaction of public business by any agency of North Carolina government or its subdivisions." Although "agency" is broadly defined, the law does not automatically reach nongovernmental bodies merely because they receive public funds or benefits. However, there are some reporting requirements for corporations, organizations or institutions that receive, use, or expend state funds. A grantee that receives between $15,000 and $300,000 in state funds annually, except when the funds are for the purchase of goods or services, must file a sworn accounting of receipts and expenditures of the state funds within six months after the end of the grantee's fiscal year in which the state funds were received. A grantee that annually receives, uses, or expends $300,000 or more in state funds, except when the funds are for the purchase of goods or services, must file an annual financial statement with the state Auditor. G.S. § 143-6.1.

If a city or county grants $1,000 or more in any fiscal year to a nonprofit corporation or organization, the city or county may require that the nonprofit have an audit performed for the fiscal year in which the funds are received and may require that the nonprofit corporation or organization file a copy of the audit report with the city or county. Any nonprofit corporation or organization that receives $1,000 or more in state funds shall, at the request of the State Auditor, submit to an audit by the office of the State Auditor for the fiscal year in which such funds were received. Every nonprofit corporation or organization which has an audit performed pursuant to this section must file a copy of the audit report with the office of the State Auditor. G.S. § 159-40.

Bodies whose members include governmental officials: Because the North Carolina Public Records Law covers only records made or received "in connection with the transaction of public business," it does not cover records of "nongovernmental groups" generally. See full OGG entry for North Carolina

North Dakota
Bodies receiving public funds or benefits: Because the open records law covers "organizations or agencies supported in whole or in part by public funds, or expending public funds," such organizations are covered by the law. A law passed in 2001 adds task forces and special advisory committees created by public entities, including university presidents, to the list of entities covered by the open meetings and records laws. N.D.C.C. § 44-04-17.1. Attorney General opinions have held that nonprofit corporations that receive public funds are public entities subject to the state's open records and open meetings laws, and that a development company funded by a public sales tax is subject to the open records laws. 2006 N. D. Op. Atty. Gen. Open Records and Meetings Opinion No. 2006-O-04; 2005 N.D. Op. Atty. Gen. Open Records and Meetings Opinion 2005-O-06. See also Letter from Attorney general Heidi Heitkamp to Representative Jennifer Ring (March 17, 1993); Guy & McDonald, "Government in the Sunshine: The Status of Open Meetings and Open Records Law in North Dakota," 53 N.D. L Rev. 51, 75-76 (1976) (discussing attorney general's opinion stating that a non-profit mental health and retardation center providing services to several political subdivisions would be subject to the open records law if it expended public funds). In Forum Publishing Company v. City of Fargo, 391 N.W.2d 169, 172 (N.D. 1986), the North Dakota Supreme Court held that a private personnel firm hired to select a new police chief for the city of Fargo was subject to the open records law. The court stated, "we do not believe the open-record law can be circumvented by the delegation of a public duty to a third party, and these documents are not any less a public record simply because they were in the possession of [the private personnel firm]." Id.

Bodies whose members include governmental officials: Such groups would be covered if and only if they are support in whole or in part by public funds or if they expend public funds. If the state or a political subdivision of the state pays a membership or other fee on behalf of the governmental official, the ground might be covered. See Adams County Record v. Greater North Dakota Association, 529 N.W.2d 830 (N.D. 1995). See full OGG entry for North Dakota

Ohio
Bodies receiving public funds or benefits: The Ohio Supreme Court has applied the statute to require public disclosure of records possessed, received, or created by private entities to which public offices had delegated the performance of public functions. State ex rel. Fostoria Daily Review Co. v. Fostoria Hospital Ass'n, 40 Ohio St. 3d 10, 531 N.E.2d 313 (1988) (minutes of meetings of board of trustees of a nonprofit corporation operating a municipal hospital pursuant to a rent-free lease); State ex rel. Plain Dealer Publishing Co. v. City of Cleveland, 99 Ohio St. 3d 1, 661 N.E.2d 187 (1996) (resumes received by private executive search firm hired by city to find candidates for post of city police chief); State ex rel. Toledo Blade Co. v. Univ. of Toledo Foundation, 65 Ohio St. 3d 258, 602 N.E.2d 1159 (1992) (records of donors to private corporation that functioned as alter-ego of state university); State ex rel. Mazzaro v. Ferguson, 49 Ohio St. 3d 37, 550 N.E.2d 464 (1990) (workpapers of a private accounting firm generated in the course of auditing the finances of a municipality); State ex rel. Findlay Publishing Company v. Hancock County Board of Commissioners, 80 Ohio St. 3d. 134, 684 N.E.2d 1222 (1997) (settlement agreement prepared by the attorney for the county's insurer); State ex rel. Freedom Communications Inc. v. Elida Community Fire Company, 82 Ohio St. 3d 578, 697 N.E.2d 210 (1998) (investigative report prepared by private, nonprofit corporation that contracted with townships to provide fire-fighting services). But see State ex rel. Farely v. McIntosh, 134 Ohio App. 3d 531, 731 N.E.2d 726 (Montgomery App. 1998) (records compiled by court-appointed psychologist are personal, not public, records).

"In order for a private entity to be subject to [the Public Records Act], (1) it must prepare the records in order to carry out a public office's responsibilities, (2) the public office must be able to monitor the private entity's performance, and (3) the public office must have access to the records for this purpose." State ex rel. Cincinnati Enquirer, Div. of Gannett Satellite Info. Network Inc. v. Krings, 93 Ohio St. 3d 654, 758 N.E.2d 1135 (2001) (correspondence related to stadium construction cost overruns kept by group of private construction contractors); State ex rel. Toledo Blade Co. v. Ohio Bureau of Workers' Comp., 106 Ohio St. 3d 113 (2005) (records related to BWC's coin investment maintained by two LLCs).

Ohio Rev. Code § 149.431 requires nonprofit corporations receiving public funds to make available to the public financial statements and the contracts pursuant to which the corporations receive the public funds.

Ohio Rev. Code § 9.92 exempts from the public records statute private organizations receiving public funds and named as official county organs to reward citizens who provide tips leading to the solving of crimes (citizen reward programs.

Bodies whose members include governmental officials: The statute does not expressly address such groups, but if such a group possesses records generated in the course of performing a duty delegated by a public office and such records may be subject to some degree of control by the office, it is likely that the records would be available to the public under the public records statute. See State ex rel. Mazzaro v. Ferguson, 49 Ohio St. 3d 37, 550 N.E.2d 464 (1990).

A hospital run by an eighteen-member board of trustees is not a "public office," notwithstanding that sixteen of the members were direct appointees of six different mayors. State ex rel. Stys v. Parma Cmty. Gen. Hosp., 93 Ohio St. 3d 438, 755 N.E.2d 874 (2001) See full OGG entry for Ohio

< previous | Alabama - Kentucky | Louisiana - Ohio | Oklahoma - Wyoming | next >