Court rules school district’s mental health survey results is a public record.

Court rules school district’s mental health survey results is a public record.

The Supreme Court of Ohio today, mandated the release of mental health survey results conducted by Crestwood Local School District. In a 6-1 per curiam decision, the Supreme Court reversed the ruling of the Eleventh District Court of Appeals denying access to a public school district’s survey of its employees.

Chief Justice Kennedy and Justices R. Patrick DeWine, Michael P. Donnelly, Melody Stewart, Jennifer Brunner, and Jospeh T. Deters joined the per curiam opinion. Justice Patrick F. Fischer dissented without a written opinion.

Background Request for Mental Health Survey Denied
ian M. Ames made a public records request to access results from a mental health survey conducted by a staff member of the Crestwood Local School District. This survey was intended to gauge the mental health and well-being of district staff and aid the school district in implementing strategies to reduce burnout and improve mental health. Despite this initiative, the district’s treasurer, acting as the custodian of records, denied Ames's request to release the survey results. The treasurer argued the results did not qualify as public records because they were not used by the school board in any decision-making process.

Ames filed a petition for a writ of mandamus with the Eleventh District, seeking to compel the Crestwood Local School District and its treasurer to release the survey results under Ohio's Public Records Act. Both parties filed motions for summary judgment, with the district presenting affidavits from key figures, including the treasurer and the district's superintendent. They claimed the survey results, which had a response rate of only 60 out of approximately 210 employees, were not used by the board and did not influence any board decisions due to their limited representation of the staff.

The Eleventh District Court of Appeals sided with the district, concluding that since the survey results were not used in conducting any official business, they did not meet the statutory definition of public records. Ames appealed this decision to the Supreme Court.

Supreme Court Took Broader View of Law
In examining the statutory definition of "public records," the Court evaluated the language of R.C. 149.43(A)(1) and R.C. 149.011(G) to ascertain whether the mental health survey results from Crestwood qualified as public records. The Court's analysis centered on three core elements stipulated in the statutes: the documentation must be created or received by a public office, kept by the public office, and serve to document the organization, functions, policies, decisions, procedures, operations, or other activities of the office.

The Court determined the survey results met all these criteria. It concluded the results were kept by the district, in the possession of the district’s treasurer, aligning with the definition of public records. The Court further reasoned the content of the survey results—detailing employees’ perceptions of how their workplace affects their mental health—provides insight into the school district's environment and operations, thus fulfilling the statutory requirement of documenting the district's functions and policies.

The  Court held the survey results did constitute public records, as they were created by the district with the superintendent's consent, related to work-related matters, and were retained by the district. The Court emphasized that records do not need to be actively used in decision-making to be public; mere possession and the potential to illuminate the district's operations suffice.

“The survey results are not merely about the 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,” the Court stated.

This ruling reversed the Eleventh District's decision and compelled the release of the survey results and to consider Ames's eligibility for statutory damages and court costs.

2023-1549. State ex rel. Ames v. Crestwood Local School Dist. Bd. of Edn., Slip Opinion No. 2024-Ohio-4889.

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