Ludlow v. Ohio Dept. of Health
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The case revolves around a public-records request made by Randy Ludlow, a reporter for the Columbus Dispatch, to the Ohio Department of Health (ODH). Ludlow requested a digital spreadsheet copy of the Electronic Death Registration System (EDRS) database, which contains information for all death certificates delivered to ODH. While ODH provided a spreadsheet with details such as decedents’ sex, age, race, birth date, marital status, and date, time, place, manner, and cause of death, it withheld the names and addresses of the decedents, claiming that this information was exempt from disclosure under R.C. 3701.17 as "protected health information."
The Court of Claims initially ordered ODH to provide the requested records, arguing that the information was not exempt from disclosure as it was public information under a different statute, R.C. 3705.23(A). However, the Tenth District Court of Appeals reversed this decision, holding that the names and addresses of the decedents, when combined with their causes of death, were properly withheld as protected health information.
The Supreme Court of Ohio affirmed the judgment of the Tenth District Court of Appeals. The court held that the names and addresses of a decedent, when combined with information regarding his or her cause of death, are protected health information under R.C. 3701.17 and are not subject to disclosure under the Public Records Act. The court noted that while this information may be obtainable under other statutes, those statutes require the requester to satisfy certain requirements before they may receive the information requested.
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