State ex rel. Fluty v. Raiff

Citations

• 172 Ohio St. 3d 542
• 225 N.E.3d 938
• 2023 Ohio 3285

Syllabus

Mandamus—Public-records requests—R.C. 149.43—Requester failed to present clear and convincing evidence establishing existence of a requested record—Requested record was not incorporated into another for purposes of Public Records Act—R.C. 149.43(B) does not require a public office to confirm delivery of a requested record—A public-records custodian may redact from an incident report identity of an uncharged suspect provided requirements of R.C. 149.43(A)(2)(a) are met—Requirements of R.C. 149.43(A)(2)(a) are met when release of record would create high probability of disclosing identity of an uncharged suspect—Public Records Act does not authorize an award of statutory damages merely because a public office cites legal authority with which requester disagrees—Writ and requests for statutory damages, attorney fees, and court costs denied.