Doe 1 v. City Of Cincinnati

CourtDistrict Court, S.D. Ohio
DecidedMay 8, 2020
Docket1:19-cv-00475
StatusUnknown

This text of Doe 1 v. City Of Cincinnati (Doe 1 v. City Of Cincinnati) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doe 1 v. City Of Cincinnati, (S.D. Ohio 2020).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

John Doe, et al.,

Plaintiffs,

v. Case No. 1:19cv475

City of Cincinnati, et al., Judge Michael R. Barrett

Defendants.

OPINION & ORDER

This matter is before the Court upon Plaintiffs’ Motion for Partial Summary Judgment (Doc. 35). The City has filed a Response in Opposition. (Doc. 36). I. BACKGROUND For purposes of the summary judgment motion, the facts are not in dispute. This case arises out of an open meetings lawsuit filed against the City. As part of the lawsuit, the private cell phones of City of Cincinnati councilmembers were copied by a firm called Binary Intelligence. The City then produced certain text messages from the copies of the cell phones. The City has retained the copies of the cell phones. Plaintiffs John Doe and Jane Doe claim the cell phones contain their private information and communications. Plaintiffs maintain that these texts, emails, and images are not public records and their disclosure violates their constitutional rights. Plaintiffs now seek summary judgment on Claim One, based on their First Amendment free speech rights, and Claim Three, based on their constitutional right of privacy. Plaintiffs also seek permanent injunctive relief barring the City from disclosing Plaintiffs’ constitutionally-protected communication as a public record. II. ANALYSIS A. Standard of Review Summary judgment is appropriate “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.”

Fed. R. Civ. P. 56(a). “The moving party has the burden of showing an absence of evidence to support the non-moving party’s case.” Celotex Corp. v. Catrett, 477 U.S. 317, 325 (1986). Once the moving party has met its burden of production, the non-moving party cannot rest on his pleadings, but must present significant probative evidence in support of his complaint to defeat the motion for summary judgment. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248-49 (1986). B. First Amendment The Supreme Court has explained that it has been “long understood as implicit in the right to engage in activities protected by the First Amendment a corresponding right to associate with others in pursuit of a wide variety of political, social, economic,

educational, religious, and cultural ends.” Roberts v. U.S. Jaycees, 468 U.S. 609, 622, 104 S.Ct. 3244, 82 L.Ed.2d 462 (1984); see also Buckley v. Valeo, 424 U.S. 1, 15, 96 S.Ct. 612, 46 L.Ed.2d 659 (1976) (per curiam) (“The First Amendment protects political association as well as political expression.”). While there is no dispute that Plaintiffs possess the right of association for the purpose of engaging in political activity, it is not clear whether the First Amendment protects their right to do so anonymously. The Sixth Circuit has upheld a requirement in a city charter that contributors to local political campaigns publicly disclose their home addresses. Frank v. City of Akron, 290 F.3d 813, 819 (6th Cir. 2002). The Sixth Circuit held that the disclosure requirement did not violate the First Amendment. Id. The Sixth Circuit found that the requirement did not unduly burden the contributors' right to association because the requirement served a significant governmental interest of providing an accountability mechanism to track campaign donors and safeguard against

corruption. Id. Here, the City argues that any burden on Plaintiffs’ right of association is outweighed by the government’s interest in transparency mandated by the Ohio sunshine laws. “Ohio's ‘Sunshine Law,’ R.C. 121.22, requires that public officials, when meeting to consider official business, conduct those meetings in public.” TBC Westlake, Inc. v. Hamilton Cty. Bd. of Revision, 81 Ohio St. 3d 58, 61, 689 N.E.2d 32, 34–35 (Ohio 1998) (quoting State ex rel. Cincinnati Post v. Cincinnati, 76 Ohio St.3d 540, 542, 668 N.E.2d 903, 905 (Ohio 1996)). Plaintiffs have not articulated a basis for this Court to find that the governmental interest served by Ohio’s Sunshine Law outweighs Plaintiffs’ right of

association in this instance. Therefore, Plaintiffs are not entitled to summary judgment on Claim One, based on their First Amendment free speech rights. C. Right of Privacy “It is firmly established that individuals have a constitutionally protected right to privacy.” Gutierrez v. Lynch, 826 F.2d 1534, 1539 (6th Cir. 1987) (citing Roe v. Wade, 410 U.S. 113, 93 S.Ct. 705, 35 L.Ed.2d 147 (1973); Griswold v. Connecticut, 381 U.S. 479, 85 S.Ct. 1678, 14 L.Ed.2d 510 (1965)). While a constitutional right to nondisclosure of certain types of private information exists, not all disclosures of private information will trigger constitutional protection. Bloch v. Ribar, 156 F.3d 673, 684 (6th Cir. 1998). The Sixth Circuit has set forth the following two-step process for analyzing informational right-to-privacy claims: “(1) the interest at stake must implicate either a fundamental right or one implicit in the concept of ordered liberty; and (2) the government's interest in disseminating the information must be

balanced against the individual's interest in keeping the information private.” Id. (citing J.P. v. DeSanti, 653 F.2d 1080, 1090 (6th Cir. 1981)).1 In this instance, it would appear that the privacy interest at stake and the government’s interest are not at odds. The City agrees that the cell phones do contain private, protected information which should never be subject to public records disclosure. (Doc 36, PAGEID # 425). Accord State ex rel. Glasgow v. Jones, 119 Ohio St.3d 391, 396, 894 N.E.2d 686, 691 (Ohio 2008) (state representative’s text messages which did not “document work-related matters” were not public records subject to disclosure under the Ohio’s Public Records Act). To the extent that Plaintiffs claim that the release of private, protected information violates their constitutional right of privacy, Plaintiffs are

entitled to summary judgment on Claim Three of their Complaint. Plaintiffs seek a permanent injunction barring the City from disclosing Plaintiffs’ constitutionally-protected communication as a public record. While Plaintiffs may not be entitled to injunctive relief setting forth a blanket prohibition against the future release of private, protected information, the procedural component of the Fourteenth Amendment's Due Process Clause at a minimum requires that the City notify Plaintiffs of a request for

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Related

Griswold v. Connecticut
381 U.S. 479 (Supreme Court, 1965)
Roe v. Wade
410 U.S. 113 (Supreme Court, 1973)
Buckley v. Valeo
424 U.S. 1 (Supreme Court, 1976)
Roberts v. United States Jaycees
468 U.S. 609 (Supreme Court, 1984)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Officer Melissa Kallstrom v. City of Columbus
136 F.3d 1055 (Sixth Circuit, 1998)
Lambert v. Hartman
517 F.3d 433 (Sixth Circuit, 2008)
State ex rel. Cincinnati Post v. City of Cincinnati
668 N.E.2d 903 (Ohio Supreme Court, 1996)
TBC Westlake, Inc. v. Hamilton County Board of Revision
689 N.E.2d 32 (Ohio Supreme Court, 1998)
State ex rel. Glasgow v. Jones
894 N.E.2d 686 (Ohio Supreme Court, 2008)
Frank v. City of Akron
290 F.3d 813 (Sixth Circuit, 2002)
Gutierrez v. Lynch
826 F.2d 1534 (Sixth Circuit, 1987)

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