The Ohio Supreme Court ruled that HIPAA does not prevent public disclosure of lead paint citations which health departments issue to property owners. State ex rel. Cincinnati Enquirer v. Daniels (March 17, 2006), 2006-Ohio-1215. The Supreme Court also defined the term "public record" to include a single document in a larger file of documents, such as an individual comp-time sheet filled out by a city employee. Kish v. Akron (March 20, 2006),2006-Ohio-1244.