Patrick v. N. Olmsted

Citations

• 2021 Ohio 2650

Syllabus

Core Terms: public record R.C. 149.43 court of claims R.C. 2743.75 non-existent moot new request. Overview: Requester sought records and information concerning a reported law enforcement incident. Respondent asserted it had provided all existing responsive records, and further that the requests failed to state a claim for which relief may be granted because each on its face was ambiguous, overly broad, and did not reasonably identify specific existing records sought. The special master found that seven of nine requests did reasonably describe documents that would constitute records, but that requester failed to establish by clear and convincing evidence that any additional responsive records existed. The special master found that a new public records request made during litigation was not actionable.