Show Notes
A family challenges the disclosure of recordings made by security cameras inside their home. A dispute between a father and son became a physical confrontation. The children's mother gave the footage to Child Protective Services, which passed it to Miami Township police. The father later pleaded guilty to a misdemeanor. Before the criminal records were sealed, the township gave a member of the public access to a redacted video in response to a records request. The children's faces were blurred and their names removed, but the family says they could still be identified and private conversations remained exposed. The father and his three children sued the township and its law director, Joseph Braun. The district court granted the defendants summary judgment, deciding the claims without a trial. The family now appeals. This is a civil privacy case, not an appeal from the father's conviction. Ohio Revised Code Section Twenty-One Fifty-One Point Four Two Three requires agencies receiving confidential child-protection information to keep it confidential, rather than release it as an ordinary public record. But violating a state confidentiality rule does not automatically establish a federal constitutional violation. Procedural due process concerns safeguards before the government takes away a protected interest. The family will argue that it needed a better chance to prevent disclosure. The township will point to its warnings, consultations with the father's lawyers, and redactions. Listen for the judges' concern that the children's interests might differ from their father's. Substantive due process raises a different question: whether the disclosure itself violated a constitutionally protected privacy right. You will hear stigma-plus, shorthand for the principle that reputational injury alone is not enough. The parties dispute whether that framework properly addresses this confidentiality claim. Qualified immunity can protect an individual official from damages when the asserted constitutional right was not clearly established. It does not protect the township itself. Separate Ohio immunity rules affect the state-law privacy claim. Robert Thompson will argue first for the family, seeking reversal. Katie Barbiere will represent the township and Braun, asking the panel to leave the judgment in place.
John Doe 1 v. Miami Township, Ohio (No. 26-3123) — U.S. Court of Appeals for the Sixth Circuit, argued October 20, 2026.
Sources:
Argument audio — official Sixth Circuit recording: https://www.opn.ca6.uscourts.gov/internet/court_audio/audio/10-20-2026%20-%20Tuesday/26-3123%20John%20Doe%201%20v%20Miami%20Township%20OH%20et%20al.mp3
Case and argument date — official Sixth Circuit audio archive: https://www.opn.ca6.uscourts.gov/internet/court_audio/aud1.php
Factual background and appealed judgment — original S.D. Ohio Doc. 64, January 27, 2026, public PDF mirror: https://cases.justia.com/federal/district-courts/ohio/ohsdce/1%3A2020cv00389/240585/64/0.pdf
Appeal and case-linked counsel — public docket, snapshot June 9, 2026: https://dockets.justia.com/docket/circuit-courts/ca6/26-3123
Confidential information shared to protect children — Ohio Revised Code 2151.423, version governing the 2019 disclosure: https://codes.ohio.gov/ohio-revised-code/section-2151.423/9-21-2006
Summary judgment — Federal Rule of Civil Procedure 56: https://www.law.cornell.edu/rules/frcp/rule_56
Due Process Clause — Fourteenth Amendment: https://www.law.cornell.edu/constitution/amendmentxiv
Professional profile published by SMBP — Katherine L. Barbiere: https://smbplaw.com/our-people/katherine-l-barbiere/
More from Oral Arguments, with Context
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