State ex rel. Parker Bey v. Byrd

Summary

The Ohio Supreme Court held that a public-records requester need not cite a specific statute or rule when making a request, but must do so when seeking a writ of mandamus to compel compliance. The court overruled *State ex rel. Husband v. Shanahan* to the extent it conflicted, and clarified that administrative court documents are subject to Sup.R. 44-47 regardless of creation date, while case documents from pre-July 1, 2009 actions are governed by the Public Records Act (R.C. 149.43). The case was remanded for the court of appeals to apply the Public Records Act to determine if the requester is entitled to mandamus, statutory damages, and costs.

Holdings

1. The court of appeals erred because the Public Records Act applies to requests for case documents from actions commenced prior to July 1, 2009, and it is not necessary to cite a specific rule or statute in a records request until the mandamus stage.
2. The court overrules State ex rel. Husband v. Shanahan to the extent it conflicts with this decision.

Questions Presented

1. Whether the court of appeals erred in denying Parker Bey's complaint for a writ of mandamus on the grounds that he did not invoke the Superintendence Rules as the basis for his request for court records.
2. Whether the court of appeals erred in denying Parker Bey's motion to strike Byrd's supplemental brief.
3. Whether the court of appeals erred in its summary judgment ruling.
4. Whether sanctions or a vexatious-litigator declaration should be imposed against Parker Bey.

Disposition

affirmed in part and reversed in part, and cause remanded