Narrative Opinion Summary
This case involves a mandamus action initiated by a relator against a Bureau of Sentence Computation, seeking compliance with a public records request and statutory damages under R.C. 149.43(C)(1) and (C)(2). The relator had submitted requests for personnel files, which went unanswered for over 16 months. The court referred the matter to a magistrate, who found the bureau's delay unreasonable and recommended statutory damages of $1,000, the maximum under the statute. The magistrate also recommended a partial writ of mandamus and granted summary judgment in part. The court adopted these findings, awarding the relator statutory damages. The motion for judgment on the pleadings was rendered moot as the bureau eventually complied with the request. The relator, as a pro se litigant, was found ineligible for attorney fees. The bureau's failure to respond within a reasonable time constituted a violation of R.C. 149.43, and while the magistrate recommended denying the relator's motion for judgment on the pleadings, the court ruled in favor of the relator regarding the statutory damages claim.
Legal Issues Addressed
Mandamus in Public Records Casessubscribe to see similar legal issues
Application: The relator sought a writ of mandamus to compel the bureau's response to his public records request, which was rendered moot once the records were provided.
Reasoning: The motion for judgment on the pleadings was denied as moot since the bureau eventually complied with the request.
Pro Se Litigants and Attorney Feessubscribe to see similar legal issues
Application: The relator was not eligible for attorney fees as a pro se litigant, and no evidence of bad faith was presented for recovering court costs.
Reasoning: While the relator sought court costs, he is ineligible for attorney fees as a pro se litigant and presented no evidence of bad faith necessary for recovering court costs.
Public Records Requests and Reasonable Timeframesubscribe to see similar legal issues
Application: The bureau's failure to respond to the public records request within a reasonable time led to statutory damages for the relator.
Reasoning: The magistrate found that the bureau did not respond to Ware's request within a reasonable timeframe, which entitled him to $1,000 in statutory damages, the maximum allowable.
Statutory Damages under R.C. 149.43(C)(1) and (C)(2)subscribe to see similar legal issues
Application: Relator was awarded statutory damages due to the bureau's delay, as the statute allows for damages of $100 per business day, capped at $1,000.
Reasoning: R.C. 149.43(C)(1) allows individuals aggrieved by delays to seek statutory damages of $100 for each business day of non-compliance, capped at $1,000, starting from the filing of a mandamus action.
Summary Judgment in Public Records Litigationsubscribe to see similar legal issues
Application: Summary judgment was granted in part due to the lack of genuine issues of material fact and the relator's entitlement to damages as a matter of law.
Reasoning: Summary judgment requires showing no genuine issues of material fact and entitlement to judgment as a matter of law.