State ex rel. Luikart v. Washington Court House

Citations

• 2026 Ohio 111

Syllabus

Mandamus—Public-records requests—R.C. 149.43(G)—A defendant's public-records request for documents from unrelated criminal case is not a request related to defendant's action for purposes of R.C. 149.43(G), and public office therefore cannot treat request as a discovery demand—Public office's purported good-faith belief that request was a discovery demand under R.C. 149.43(G) does not change that reasonableness of response time is measured by date of request, not date that public office's motion for judgment on pleadings was denied—Multiple emails sent on the same calendar day to the same office all concerning docket items in cases filed in city's municipal court relate to the same general subject matter, thus constituting one transmission for purposes of statutory damages—Public office failed to establish that its reliance on R.C. 149.43(G) warranted reducing or denying statutory-damages award—Writ denied as moot and relator awarded $1,000 in statutory damages.