Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's petition for a writ of mandamus against the Hamilton County clerk of courts (Appellee) to compel the production of public records and awarded him $700 in statutory damages, holding that Appellant failed to prevail on his claims.Appellant, an inmate, sent public records requests to the clerk, who informed Appellant that his requests were subject to approval from the judge who sentenced him or their successor according to Ohio Rev. Code 149.43(B)(8). Appellant filed a petition for a writ of mandamus challenging the clerk's response. The petition was dismissed, but the Supreme Court reversed. On remand, Appellant filed a motion for default judgment. The court of appeals denied both Appellant's motion for default judgment and his petition for a writ of mandamus. The Supreme Court affirmed and awarded statutory damages, holding that Appellant had prevailed on his claims to the extent the law allowed. View "State ex rel. Ware v. Parikh" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting Appellant's petition for a writ of mandamus but denying his requests for statutory damages and court costs, holding that there was no error.Appellant, an inmate, sent a public-records request to Appellee, an employee of a private company that contracts with the state of Ohio to house state prisoners. Dissatisfied with the ultimate response, Appellant filed the current action asking for a writ of mandamus ordering Appellee to produce the records requested. The court of appeals granted the writ to a limited extent and denied Appellant's request for statutory damages and court costs. The Supreme Court affirmed, holding that the court of appeals did not err in denying Appellant's request for statutory damages and court costs. View "State ex rel. Atakpu v. Shuler" on Justia Law

The Supreme Court granted in part and denied in part the Lawrence County Sheriff's Office's motion for judgment on the pleadings as to this action brought by Relator, an inmate, and denied as moot Relator's claim for a writ of mandamus, holding that the mandamus claim was moot.Relator sought certain records from the Lawrence County Sheriff's Office, which determined that the request was too vague to grant. Relator then filed this action requesting, among other things, a writ of mandamus ordering the Sheriff to produce the requested records and seeking awards of statutory damages, attorney fees, and court costs. The Sheriff filed a motion for judgment on the pleadings. Thereafter, Relator received the requested records. The Supreme Court held (1) the Sheriff was entitled to judgment on the pleadings as to Relator's mandamus claim, which was moot; (2) Relator was entitled to $700 in statutory damages but was not entitled to attorney fees and court costs; and (3) Relator's remaining motions were moot. View "State ex rel. Woods v. Lawrence County Sheriff's Office" on Justia Law

The Supreme Court granted a writ compelling the Mansfield Correctional Institution to produce records requested by Relator against the Mansfield Correctional Institution under Ohio's Public Records Act, Ohio Rev. Code 149.43, holding that Relator was entitled to a writ.Relator requested information and records from the prison warden's office regarding three assaults committed against her son while he was incarcerated at the prison. After the prison asserted that all responsive records had been produced Relator brought this action. The Supreme Court granted the writ with respect to some of the requested records and granted a limited writ compelling the prison to produce additional requested records or to certify that no responsive records existed and denied Relator's motions to transfer this case to the court of claims, to strike the prison's merit brief, and other motions, holding (1) the prison failed to prove that certain withheld information fell squarely within an exception to the Act; (2) the prison did not carry its burden of proving that no other documents existed that were responsive to certain requests; and (3) Relator was not entitled to a writ of mandamus as to the remaining evidence. View "State ex rel. Sultaana v. Mansfield Correctional Institution" on Justia Law

The Supreme Court granted a writ of mandamus sought by Matthew Lusane against the city of Kent police department, holding that Lusane was entitled both to the writ and to $1,000 in statutory damages.In 2022, Lusane delivered a public records request to the police department seeking all officer body cameras and cruiser dash camera video related to a certain incident. The department denied the request, stating that the videos fell under the public records disclosure exception for confidential law enforcement investigatory records. Lusane then filed this action requesting a writ of mandamus and seeking an award of statutory damages. The Supreme Court granted both the writ and awarded statutory damages, holding (1) the department improperly denied Lusane a copy of the videos; and (2) Lusane was entitled to $1,000 in statutory damages. View "State ex rel. Lusane v. Kent Police Dep't" on Justia Law

The Supreme Court granted in part and denied in part a writ of mandamus requested by Relator, an inmate at the Trumbull Correctional Institution, against Respondents, including Anthony Davis, (collectively, TCI) seeking production of records responsive to six public-records requests he sent in June 2021, holding that Relator was entitled, in part, to mandamus.By way of six messages, Relator requested four records. As to the first record, the Supreme Court denied mandamus on the ground that Relator failed to establish that Davis was the custodian of the record in question. As to the remaining three requested records, the Supreme Court held that TCI breached a statutory obligation to provide Relator with the records. The Court then awarded Relator $3,000 in statutory damages, holding that Relator satisfied the method-of-transmission requirement for an award of statutory damages. View "State ex rel. Ware v. Wine" on Justia Law

The Supreme Court held that Netflix Inc. and Hulu, LLC (together, Defendants) were not video-service providers under the Fair Competition in Cable Operations Act, Ohio Rev. Code 1332.21 (the Act) and that the Act did not expressly or impliedly give the City of Maple Heights the authority to bring a cause of action such as the one at issue in this case.The City of Maple Heights filed a federal class action and declaratory judgment lawsuit against Netflix and Hulu in federal court asserting that Defendants were in violation of the Act. Defendants moved separately to dismiss the complaint on the grounds that their streaming services did not fall within the Act. The federal court certified two state-law questions for Supreme Court review. The Court answered (1) Netflix and Hulu were not service providers under Ohio law; and (2) the Act did not grant Maple Heights either an express or an implied right to bring an action against Defendants to enforce Ohio's video service provider provisions. View "City of Maple Heights v. Netlix, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against Baker, Dublikar, Beck, Wiley & Mathews (the Baker firm), Public Entity Risk Services of Ohio (PERSO), and the Ohio Township Association Risk Management Authority (OTARMA) seeking to obtain unreacted copies of invoices that the Baker firm had prepared for PERSO, holding that the court of appeals did not properly apply the standard of review in dismissing Appellant's petition.Appellant brought this action under Ohio's Public Records Act, Ohio Rev. Code 149.43, seeking a writ of mandamus ordering Appellees to produce unreacted copies of the requested records. The court of appeals determined that Appellees were subject to the Act despite their private-party status but dismissed the petition on the ground that the records were protected by the attorney-client privilege. The Supreme Court reversed, holding (1) PERSO was not immune from suit; and (2) the court of appeals department from the Civ.R. 12(B)(6) standard. View "State ex rel. Ames v. Dublikar, Beck, Wiley & Mathews" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying a writ of mandamus compelling the city of Cleveland to disclose use-of-force (UOF) reports on the grounds that UOF reports are exempt from disclosure under the Public Records Act, Ohio Rev. Code 149.43, as confidential law-enforcement investigatory records (CLEIR), holding that the court of appeals erred.UOF reports are prepared whenever a Cleveland police officer uses force in the course of the officer's duties. Appellants brought this mandamus action against Cleveland seeking disclosure of the reports. The court of appeals denied the requested writ, holding that the reports were exempt as CLEIR. The Supreme Court reversed, holding that Cleveland did not meet its burden to prove that the exception at issue applied to the specific information contained in the reports. View "State ex rel. Standifer v. Cleveland" on Justia Law

The Supreme Court granted in part writs of mandamus and prohibition against Ronald P. Forsthoefel, a judge on the Ashland County Common Pleas Court, barring Judge Forsthoefel from enforcing his order sealing the documents filed in an underlying dissolution case and ordering him to vacate his sealing order and to conduct a proper review of the documents.The Cincinnati Enquirer requested a writ of mandamus ordering Judge Forsthoefel to vacate his order sealing documents in the dissolution case and to permit public access to the documents and also sought a writ of prohibition barring the judge from enforcing his sealing order. The Supreme Court granted the requested writs in part, holding (1) the Enquirer was entitled to a writ of mandamus ordering Judge Forsthoefel to vacate his sealing order and to conduct a proper review of the documents subject to the sealing order; and (2) the Enquirer was entitled to a writ of prohibition because it had shown entitlement to a writ of mandamus. View "State ex rel. Cincinnati Enquirer v. Forsthoefel" on Justia Law