State ex rel. Wilson-Simmons v. Lake Cty. Sheriff's Dept

In State ex rel. Wilson-Simmons v. Lake Cty. Sheriff's Dept. (1998), 82 Ohio St.3d 37, 693 N.E.2d 789, it was held that e-mail generated within a county sheriff's department that allegedly contained racial slurs against an employee were not "records" within the meaning of R.C. 149.011(G) because there was no evidence that they documented department policy or procedures. The e-mail was allegedly circulated only to a few coworkers and was not used to conduct sheriff's department business. Although the alleged raciest e-mail was created by public employees, via a public office's e-mail system, it was never used to conduct the business of the public office and did not constitute records for purposes of R.C. 149.011(G).