Thompson v. Tiffin City Schools

2026 Ohio 916
CourtOhio Court of Claims
DecidedFebruary 24, 2026
Docket2025-00892PQ
StatusPublished

This text of 2026 Ohio 916 (Thompson v. Tiffin City Schools) is published on Counsel Stack Legal Research, covering Ohio Court of Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thompson v. Tiffin City Schools, 2026 Ohio 916 (Ohio Super. Ct. 2026).

Opinion

[Cite as Thompson v. Tiffin City Schools, 2026-Ohio-916.]

IN THE COURT OF CLAIMS OF OHIO

AARON D. THOMPSON Case No. 2025-00892PQ

Requester Special Master Sarah Pierce

v. REPORT AND RECOMMENDATION

TIFFIN CITY SCHOOLS

Respondent

{¶1} This matter is before me for a report and recommendation. R.C.2743.75(F). I recommend that the court (1) deny as moot respondent’s motion to dismiss, (2) order respondent to produce records as detailed in this report and recommendation, (3) order respondent to reimburse requester’s filing fee, (4) order respondent to bear the remaining costs of this case, and (5) deny any other relief. I. Background A. The public records requests {¶2} This case concerns three public records requests made by Requester Aaron Thompson to the Tiffin City Schools. Complaint, filed Oct. 24, 2025, p. 1. {¶3} First Request. On October 18, 2022, Requester’s attorney, Gina Grandillo, submitted a public records request to the Schools. Compl., p. 2, 4. The request asked for “all emails sent and received from Tiffany Thompson, from December 11, 2021 through December 19, 2021.” Compl., p. 4. The Schools provided the requested records to the attorney on November 18, 2022. Compl., p. 2, 22, 73. {¶4} On November 30, 2022, Requester submitted his own public records request for the same records. Compl., p. 2, 74. On December 6, 2022, the Schools provided responsive records. Compl., p. 2, 111. Redactions were made to “personally identifiable student information.” Compl., p. 111. {¶5} After follow-up from the Requester, and in consultation with the Schools’ legal counsel, the Schools provided another production of responsive records to Requester on Case No. 2025-00892PQ -2- REPORT AND RECOMMENDATION

December 8, 2022. Compl., p. 2, 113. This record production included a few additional emails that the Schools identified as responsive public records. Id. Redactions were again made to “[a]ll personally identifiable student (other than your children) information.” Id. {¶6} Second Request. On June 7, 2025, Requester submitted a second public records request to the Schools. Compl., p. 2, 156-57. On June 30, 2025, the Schools responded to the second request with records. Compl., p. 165. Redactions were made to “personally identifiable student information” and “[p]ersonal cell phone numbers.” Id. {¶7} After this response, Requester realized that he had misstated the timeframe for his request, asking for 2022 instead of 2021. Compl., p. 2. On July 7, 2025, Requester modified his request to address the error. Compl., p. 2, 192-193. This modified request asked for: All emails sent or received by Tiffany Thompson between 6:30 AM on December 13, 2021 and 12:00 AM on December 18, 2021, where the other party to the communication was: • Melissa Mellott • Ailey Thompson • Erin Lawrence • Anna Trausch • Trisha Eidt[.] Please include all message content, attachments, and metadata (e.g., sender/recipient fields and timestamps). Compl., p. 192-194. {¶8} On July 10, 2025, the Schools provided a response to the modified request. Compl., p. 2, 195-196. No records were provided. Id. {¶9} Third Request. That same day, July 10, 2025, Requester submitted a third public records request. Compl., p. 3, 198. This request asked for: 1. A copy of any public records request submitted by Gina Grandillo to Tiffin City Schools, including but not limited to email communications, forms, or written correspondence; 2. All communications sent to or received from Gina Grandillo by any employee of Tiffin City Schools in connection with her request, including internal emails referencing or discussing the request; 3. All documents, records, or materials provided to Ms. Grandillo in response to her request, including any attachments or responsive files from 11/1/22- 11/30/22. 4. Any communications or notes from Tiffin City Schools staff or Case No. 2025-00892PQ -3- REPORT AND RECOMMENDATION

legal counsel related to the review, redaction, or production of records responsive to Ms. Grandillo’s request. Compl., p. 198. Requester clarified that the “request likely occurred between October 1, 2022, and November 30, 2022.” Id. {¶10} On July 23, 2025, the Schools responded to the third request and provided records. Compl., p. 201-204. After follow-up from Requester, the Schools provided additional responsive records on August 8, 2025. Compl., p. 3, 209-210, 211-279. B. Procedural history {¶11} This matter was referred to mediation. Mediation did not resolve the case, and a schedule was set for both parties to file evidence and memoranda supporting their positions. That schedule has run its course, making this case ripe for decision. Order Terminating Mediation, entered Dec. 30, 2025. II. Analysis A. Respondent’s motion to dismiss should be dismissed as moot. {¶12} The Schools filed a motion to dismiss the complaint. Resp. MTD, filed Jan. 23, 2026. The motion essentially urges dismissal because the case is moot. Therefore, the Schools’ motion should be considered a response to the complaint and denied as moot. Hicks v. Village of Newtown, 2018-Ohio-1540, ¶ 13 (Ct. of Cl.). The substance of the motion is addressed below as a response to the complaint. B. Requester is entitled to relief on his first request. {¶13} Redaction/Withholding. On December 8, 2022, Requester was provided with the final production of records responsive to his first request. Requester contests the Schools’ redactions to these records and its withholding of other, responsive material. {¶14} If records are withheld from release based on a public records exception, the public office must “prove facts clearly establishing the applicability of the exception.” Welsh-Huggins v. Jefferson Cty. Prosecutor’s Office, 2020-Ohio-5371, ¶ 27. The public office “does not meet [its] burden if it has not proven that the requested records fall squarely within the exception” and courts “resolve any doubt in favor of disclosure.” (Cleaned up.) Id. at ¶ 27. The public office must produce extrinsic evidence if the applicability of the exception is “not obviously apparent and manifest just from the content of the record itself.” Id. at ¶ 35. Case No. 2025-00892PQ -4- REPORT AND RECOMMENDATION

{¶15} I have reviewed the disputed records in camera. The exceptions claimed by the Schools are each addressed below. A summary of these findings can be found at Appendix A to this report and recommendation. {¶16} Student records. The Schools redacted student information pursuant to R.C. 3319.321, Ohio’s Student Privacy Act (OSPA), and FERPA, the federal Family Educational Rights and Privacy Act (20 U.S.C. § 1232g). {¶17} FERPA prohibits federally funded educational institutions from releasing “education records” without proper consent. 20 U.S.C. §1232g(b). The Schools’ most recent audit documents that the Schools receive federal funding. Ohio Auditor of State, Tiffin City School District, Seneca County, single Audit for the year ended June 30, 2024, (released Mar. 27, 2025).1 While the Schools did not introduce this evidence, I take judicial notice of that fact. State ex rel. Pike Cty. Convention & Visitor’s Bur. v. Pike Cty. Bd. of Comm’rs, 2021-Ohio-4031, ¶ 3 n.2. The Schools must therefore comply with FERPA. State ex rel. ESPN, Inc. v. Ohio State Univ., 2012-Ohio-2690, ¶ 25. {¶18} “For purposes of FERPA, the term ‘education records’ means ‘those records, files, documents, and other materials which—(i) contain information directly related to a student; and (ii) are maintained by an educational agency or institution or by a person acting for such agency or institution.’” State ex rel. ESPN, Inc. at ¶ 27.

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Bluebook (online)
2026 Ohio 916, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thompson-v-tiffin-city-schools-ohioctcl-2026.