Summary
The Ohio Supreme Court held that requests for public records from a court are governed exclusively by the Rules of Superintendence for the Courts of Ohio (Sup.R. 44–47), not the Ohio Public Records Act (R.C. 149.43). The court affirmed the dismissal of an incarcerated inmate's mandamus petition, even though the lower court erroneously applied R.C. 149.43(B)(8), because a correct judgment will not be reversed. The concurrence emphasized that the substantive limits of R.C. 149.43(B)(8) still apply to inmates seeking court records, requiring a sentencing court's release before access.
Topics
Practice areas
Questions Presented
- Whether the court of appeals correctly dismissed the mandamus petition; whether the Public Records Act or the Rules of Superintendence apply to an incarcerated person's request for court records; and whether the inmate must obtain a release from the sentencing court under R.C. 149.43(B)(8).
Holdings
- The court of appeals' judgment is affirmed. The Rules of Superintendence for the Courts of Ohio, specifically Sup.R. 44 through 47, are the sole vehicle for obtaining public records from a court. Therefore, Husband's request under the Public Records Act was improper, and the dismissal was correct, albeit on different grounds.
Key quotations
“When a requester seeks public records from a court, the Rules of Superintendence for the Courts of Ohio apply.” (¶ 5)
“Sup.R. 44 through 47 deal specifically with the procedures regulating public access to court records and are the sole vehicle for obtaining such records in actions commenced after July 1, 2009.” (¶ 5)
“Although the court of appeals’ rationale for dismissing this case was incorrect, we will not reverse a correct judgment.” (¶ 6)
Factual background
In 2006, Husband was convicted of aggravated burglary, abduction, and rape and sentenced to 65 years in prison. In April and July 2016, he filed motions in the trial court under R.C. 149.43 seeking inspection and release of public records related to his case. The trial court denied the motions, noting that Husband could access publicly available records through the clerk of courts. In January 2018, Husband filed a petition for a writ of mandamus in the court of appeals to compel Judge Shanahan to release the records. The court of appeals dismissed the petition, holding that Husband, as an incarcerated person, was subject to R.C. 149.43(B)(8) and had not obtained the required release.
Procedural history
Husband filed a petition for a writ of mandamus in the First District Court of Appeals to compel Judge Shanahan to release court records. The court of appeals granted the motion to dismiss, holding that Husband, as an incarcerated person, was subject to R.C. 149.43(B)(8) and had not obtained the required release from the sentencing court. Husband appealed.