State ex rel. Harris v. Copley

Summary

The Sixth District Court of Appeals dismissed John Harris’s petition for a writ of mandamus against a Toledo Correctional Institution business office supervisor. The court held that Harris’s requests for the full names of three officers sought information rather than specific public records and therefore did not constitute valid requests under Ohio’s Public Records Act. The court dismissed the petition with prejudice and assessed costs to Harris.

Holdings

1. A request for the names of three officers, without requesting a specific existing record such as the database or list maintained under R.C. 149.434(A), is a request for information rather than a valid public-records request under R.C. 149.43.
2. Because Harris did not submit a valid public-records request, he could not demonstrate a clear legal right to the requested information or a clear legal duty on Copley’s part to provide it.
3. The Civ.R. 12(B)(6) motion was well taken, and Harris's mandamus petition was dismissed with prejudice.

Questions Presented

1. Whether Harris's requests for the full names of three officers constituted valid public-records requests under R.C. 149.43.
2. Whether Harris could establish a clear legal right to the requested information and a clear legal duty requiring Copley to provide it.
3. Whether Copley's Civ.R. 12(B)(6) motion should be granted.

Disposition

dismissed