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· 4/23/2026

State ex rel. Howard v. Chief Inspector's Office

Citations

  • 2026 Ohio 1428

Syllabus

Mandamus—Public-records requests—R.C. 149.43—A public office has a clear legal duty to produce public records only when it has fair notice that it has received a public-records request; the requester has the burden to show that he clearly submitted a public-records request—Whether a request is a public-records request may depend on the context in which the request was made—Request for records made in an inmate's grievance appeal under Adm.Code 5120-9-31 was not clearly a public-records request—Public office permitted to argue for first time in litigation that inmate did not clearly make a public-records request—Writ and requests for statutory damages and court costs denied.

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