Georgia, North Carolina, and Virginia (and as of Thursday, Ohio) are the only states that require private college police departments to release records, according to the Student Press Law Center. On Thursday, the Ohio Supreme Court took the approach opposite to Indiana, holding that a private college institution does not preclude its police department from being a public office. In that case, an Otterbein student reporter sued the university (I applaud her for her tenacity, somebody hire her!) after it denied her request for police records, claiming that the University is a private institution and its police records are not subject to Ohio's public records laws. The Ohio Supreme Court found in favor of the student, ruling that the records were public. You can read about the decision here.
The Supreme Court of Ohio is among the first in what is believed to be a trend where eventually all private universities’ police records, nationwide, will be made public. Where an agency and its members gets its power from the state, which sworn campus police officers do, the agencies' records should be public. I believe the Ohio Supreme Court definitely got this one right.