State ex rel. Hill v. Adult Parole Officer Campbell

Summary

The Tenth District Court of Appeals of Ohio granted Robert Hill a limited writ of mandamus concerning his public-records requests to the Ohio Department of Rehabilitation and Correction. The court adopted the magistrate's factual findings but rejected its legal conclusions that the requested records were exempt as records of inmates or did not exist. It ordered ODRC to research the resource material relied upon to determine Hill's ineligibility for transitional control.

Holdings

1. The interpretation of "records of inmates" adopted in State ex rel. Hogan Lovells U.S., L.L.P. v. Ohio Department of Rehabilitation and Correction does not extend to records that relate to the inmate seeking them himself and that form the basis for the denial of his transitional-control eligibility. Such records are not exempt from disclosure under R.C. 5120.21(F) on that basis.
2. The court could not accept, without further exploration or explanation, ODRC's averment that the requested judgment entries, sentencing entries, and related documents or resource material did not exist.
3. Hill was entitled to a limited writ of mandamus requiring ODRC to research the resource material on which Campbell and the Ohio Adult Parole Authority based the determination that Hill was ineligible for transitional control.

Questions Presented

1. Whether records requested by an inmate concerning himself and the basis for his transitional-control ineligibility determination are "records of inmates" exempt from public-records disclosure under R.C. 5120.21(F).
2. Whether the court could accept, without further exploration or explanation, ODRC's assertion that the requested judgment entries, sentencing entries, or related resource material did not exist.
3. Whether Hill was entitled to a limited writ of mandamus compelling ODRC to research and provide the resource material underlying the ineligibility determination.

Disposition

remanded