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State ex rel. Callos Staffing Co., L.L.C. v. Ohio Dept. of Job & Family Servs.

Citation: 2011 Ohio 3662Docket: 11 MA 5

Court: Ohio Court of Appeals; July 13, 2011; Ohio; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

Callos Staffing Company, LLC initiated a mandamus action against the Ohio Department of Job and Family Services on January 12, 2011, seeking access to documents related to an audit of its unemployment insurance records. The Department responded by asserting the records were not public under R.C. 4141.21, which excludes certain records from public disclosure. The court affirmed that for a writ of mandamus to be granted, the relator must show a clear legal right to the requested relief, a corresponding duty by the respondent, and no adequate remedy under the law. Because the requested records are exempt from public access, the court dismissed the complaint, imposing costs on the relator. The decision was unanimous among the judges.

Legal Issues Addressed

Dismissal of Mandamus Complaint

Application: The court dismissed Callos Staffing Company's mandamus action due to the exemption of the requested records from public access, thereby negating the company’s claim of a clear legal right to the documents.

Reasoning: Because the requested records are exempt from public access, the court dismissed the complaint, imposing costs on the relator.

Mandamus Relief Requirements

Application: The court underscored that a writ of mandamus requires the relator to demonstrate a clear legal right to the relief sought and a corresponding duty by the respondent, along with the absence of an adequate legal remedy.

Reasoning: The court affirmed that for a writ of mandamus to be granted, the relator must show a clear legal right to the requested relief, a corresponding duty by the respondent, and no adequate remedy under the law.

Public Records Exemption under R.C. 4141.21

Application: The Ohio Department of Job and Family Services successfully argued that the unemployment insurance records requested by Callos Staffing Company were exempt from public disclosure under the specific statutory provision.

Reasoning: The Department responded by asserting the records were not public under R.C. 4141.21, which excludes certain records from public disclosure.