The Supreme Court of Ohio has mandated the release of mental health survey results conducted by Crestwood Local School District. The decision, reached with a 6-1 vote, reversed an earlier ruling by the Eleventh District Court of Appeals that denied access to these records.
Chief Justice Kennedy and Justices R. Patrick DeWine, Michael P. Donnelly, Melody Stewart, Jennifer Brunner, and Joseph T. Deters supported the majority opinion. Justice Patrick F. Fischer dissented but did not provide a written opinion.
The case originated when Ian M. Ames requested access to the results of a mental health survey aimed at assessing staff well-being in Crestwood Local School District. This survey was intended to help develop strategies for reducing burnout and improving mental health among district employees. However, the request was denied by the district’s treasurer, who argued that since the results were not used in any school board decisions, they did not qualify as public records.
Ames responded by filing a petition for a writ of mandamus with the Eleventh District to compel release under Ohio's Public Records Act. Despite this effort, the court sided with the district because it found that unused data did not meet public record criteria.
Upon appeal to the Supreme Court, broader statutory interpretations were considered regarding "public records." The Court evaluated whether such documents must be created or received by a public office and maintained as part of its functions or activities. It concluded that even if not used in decision-making processes, documentation like survey results can still offer insight into organizational operations.
“The survey results are not merely about employees’ general mental health; they document employees’ responses to inquiries about how their mental health is negatively affected by the workplace and how well the school district or individual schools support the employees,” stated the Court.
The Supreme Court's ruling reversed prior decisions and mandated releasing these records while also addressing potential damages and costs owed to Ames under statutory provisions.