Castellon v. Ohio Dept. of Rehab. & Corr.

Citations

• 2025 Ohio 4747

Syllabus

Defamation; Qualified Privilege; Negligence; Public Records; Breach of Contract/Promissory Estoppel. Plaintiff, a former inmate, brought multiple claims against Ohio Department of Rehabilitation and Correction (\ODRC\) after he was charged with institutional rule violations based on written communications he sent to prison officials criticizing the cancellation of Hispanic Heritage Month events. The Chief of Security authored a conduct report characterizing Plaintiff's statements and subsequent discussion as \implied\ or \vague\ threats, resulting in Plaintiff's placement in restricted housing and later transfer. Plaintiff alleged that the statements in the conduct report were defamatory and that an Institutional Inspector wrongfully withheld records necessary to pursue his claims. On cross-motions for summary judgment, the Court found that the statements reflected opinion—not verifiable fact—and were protected by qualified privilege, as they were made in good faith within the scope of official duties and limited to appropriate prison staff. Plaintiff offered no evidence of actual malice sufficient to overcome the privilege. The Court also dismissed the abuse of process claim (which Plaintiff had withdrawn), the intentional tort claim (as duplicative of the defamation theory and jurisdictionally barred insofar as it challenged housing and transfer decisions), the negligence claim (because alleged violations of public records law must be pursued through mandamus or an R.C. 2743.75 action, not negligence), and the breach of contract/promissory estoppel claim (because no contract or enforceable promise existed, and statutory duties under the Public Records Act do not create contractual rights). The Court therefore granted Defendant's Motion for Summary Judgment, denied Plaintiff's Motion for Summary Judgment, and entered judgment in favor of Defendant.