State ex rel. Ctr. for Media & Democracy v. Yost

Citations

• 2026 Ohio 1899

Syllabus

Mandamus—Public-records requests—Discovery—In public-records mandamus action, court of appeals issued discovery order compelling responses to interrogatories and requests for production of documents and ordering attorney general to appear for deposition—Discovery in a public-records mandamus action must be restricted to conform with the purpose of discovery set forth in Civ.R. 26(A) and the scope of discovery set forth in Civ.R. 26(B)(1)—When requested records cannot be or have not been produced, courts should limit discovery in a public-records mandamus action to the nature of the public office's search for responsive records and to information relevant to the claims and defenses asserted by the parties—When requested records exist and can be produced but the parties dispute whether the records should be produced, any discovery must be confined by the claims asserted by the requester and the defenses asserted by the public office relative to producing the records—In issuing its discovery order, the court of appeals misapplied the law and abused its discretion in determining the correct scope of discovery under Civ.R. 26(B)(1) in context of a public-records mandamus action and in ordering deposition of a high-ranking government official—Court of appeals' discovery order vacated and cause remanded for proper consideration of discovery requests.