State ex rel. Parker Bey v. Loomis

Summary

The Supreme Court of Ohio reversed the dismissal of Vincent El Alan Parker Bey’s mandamus action seeking public records from the Trumbull Correctional Institution. The court held that the request was not moot because the respondents had sought additional information to locate the requested records and had not shown compliance with the request. The case was remanded for further proceedings, including consideration of statutory damages and court costs.

Holdings

1. The claim was not moot because the institution's undated letter showed that it was requesting additional information to locate the records, and the institution presented no evidence that it had complied with the second part of the request.
2. Because Parker Bey sent his public-records request by certified mail, he may be entitled to statutory damages if the court of appeals determines on remand that Loomis failed to respond timely or fully. If the court grants a writ concerning the second part of the request, Parker Bey will also be entitled to court costs under the applicable former statute.

Questions Presented

1. Whether Parker Bey's public-records mandamus claim was moot when the record did not show that the institution had complied with the second part of his records request.
2. Whether Parker Bey could potentially recover statutory damages and court costs on remand based on his certified-mail public-records request.
3. Whether the court of appeals improperly granted a motion to dismiss without converting it to a motion for summary judgment.

Disposition

reversed_and_remanded