Summary
The Supreme Court of Ohio granted a writ of mandamus requiring the respondents to prepare and produce minutes of previously held Brownfield Committee meetings at which a majority of the members discussed public business. The court held that Avon Lake Community Improvement Corporation and its Brownfield Committee were subject to Ohio’s open-meetings and public-records requirements. The court awarded court costs but denied attorney fees and statutory damages, and denied or found moot the parties’ additional motions.
Court
Supreme Court of Ohio
Jurisdiction
Supreme Court of Ohio
Decision date
March 31, 2026
Docket number
2024-1711
Disposition
writ_granted
Questions Presented
- Whether mandamus was a proper remedy for compelling preparation and production of minutes for previously held Brownfield committee meetings.
- Whether R.C. 121.22(C) and R.C. 149.43 applied to the Avon Lake Community Improvement Corporation despite Avon Lake's charter and home-rule authority.
- Whether the Avon Lake Community Improvement Corporation was a public body subject to the Ohio Open Meetings Act.
- Whether the Brownfield Funding Committee was a committee of a public body and therefore subject to R.C. 121.22(C), even though it lacked delegated decision-making authority.
- Whether relators were entitled to court costs, attorney fees, and statutory damages.
Holdings
- Mandamus is proper when the relator seeks to compel respondents to prepare and produce minutes for previously held public-body meetings; the requested relief was mandatory rather than declaratory or prohibitory.
- R.C. 121.22(C) applied to Avon Lake and the Avon Lake Community Improvement Corporation because no charter provision or city ordinance expressly conflicted with or superseded the statute.
- The Avon Lake Community Improvement Corporation was a public body subject to R.C. 121.22(C), and some of its records were subject to disclosure under R.C. 149.43.
- The Brownfield Funding Committee was a committee of the Avon Lake Community Improvement Corporation and therefore a public body subject to R.C. 121.22(C), even though it was advisory and lacked delegated decision-making authority.
- Relators were entitled to a writ requiring respondents to prepare and produce minutes for previously held Brownfield committee meetings attended by a majority of its members at which public business was discussed.
- Relators were not entitled to attorney fees or statutory damages because they forfeited those claims by failing to support them with arguments in their merit brief.
Court Document
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