Summary
The Supreme Court of Ohio considers an inmate’s mandamus action seeking public records from the Ohio Department of Rehabilitation and Correction. The court grants a limited writ requiring ODRC either to provide the inmate’s master file, subject to lawful redactions, or certify that it does not possess one; it denies relief concerning the other requests, defers statutory-damages determination, and denies court costs. A partial dissent disputes the treatment of correction officers’ work schedules as exempt security records and the majority’s approach to statutory damages.
Court
Supreme Court of Ohio
Jurisdiction
Supreme Court of Ohio
Decision date
February 18, 2026
Docket number
2024-1169
Disposition
writ_granted
Questions Presented
- Whether ODRC's post-suit production of responsive records rendered some of Lawrence's mandamus claims moot.
- Whether Lawrence abandoned requests for mandamus relief by failing to argue them in his merit brief.
- Whether ODRC could deny Lawrence's request for his master file because no master file was stored at Toledo Correctional Institution.
- Whether correction-officer work schedules and posts were exempt security records under R.C. 149.433.
- Whether ODRC had a duty to create a new list or compilation of correction officers or conduct-report history to satisfy Lawrence's requests.
- Whether Lawrence was entitled to statutory damages and court costs.
Holdings
- Providing requested records after a public-records mandamus action is filed generally renders the corresponding mandamus claim moot.
- The court need not grant mandamus relief on a public-records request raised in the complaint but not specifically argued in the merit brief.
- A correctional institution may not deny an inmate's request for the inmate's master file solely because the file is not stored at that institution; if ODRC possesses the file, it must produce it subject to lawful redactions, or certify that it is not in possession of the file.
- Correction-officer work schedules and posts are security records exempt from production under R.C. 149.433.
- A public office does not have a duty to create a new record or compilation to satisfy a public-records request.
- The determination of statutory damages for the master-file request is deferred until ODRC complies with the limited writ.
Court Document
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