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Ohio Supreme Court Affirms Denial of Public Records Damages to Prisoner
On December 1, 2010, the Supreme Court of Ohio issued and opinion affirming a court of appeals decision denying statutory damages to a prisoner who prevailed against prison officials in a public records mandamus action.
Lambert Dehler, an Ohio state prisoner, submitted a public records request for prison library records pursuant to R.C. 149.43. The prison refused to allow Dehler to view the requested records and refused to provide copies of the records unless Dehler prepaid copying fees which Dehler refused to do. Dehler filed a petition for a writ of mandamus in a court of appeals. The court of appeals granted a writ of mandamus to compel prison officials to immediately satisfy Dehler's request for access to the records. R.C.149.43(C)(1) provides for $1,000 in statutory damages if the public officials "failed to perform their legal duties under R.C. 149.43(B) to provide access to those records." Even though prison officials had failed to provide access to the records for more than ten days, which would have resulted in the maximum fine of $1,000, the court of appeals denied Dehler the statutory damages because Dehler had another mandamus action pending in an unrelated public records request. Dehler appealed.
The Ohio Supreme Court held that the court of appeals was right, but for the wrong reasons. Stating that prison officials were not required to provide inspection of public records if it might unreasonably interfere with the discharge of their duties, the Supreme Court held that Dehler should have prepaid the copying fees and his failure to do so relieved prison officials of liability for the statutory damages. The Supreme Court also noted that "R.C. 149.43(C)(1) did not permit stacking of statutory damages based on what is essentially the same records request." Therefore, it affirmed the judgment of the court of appeals denying the award. Justice Brown filed a dissenting opinion. See: State ex rel. Dehler v. Kelly, S.Ct. Ohio, No. 2010-Ohio-5724.
Lambert Dehler, an Ohio state prisoner, submitted a public records request for prison library records pursuant to R.C. 149.43. The prison refused to allow Dehler to view the requested records and refused to provide copies of the records unless Dehler prepaid copying fees which Dehler refused to do. Dehler filed a petition for a writ of mandamus in a court of appeals. The court of appeals granted a writ of mandamus to compel prison officials to immediately satisfy Dehler's request for access to the records. R.C.149.43(C)(1) provides for $1,000 in statutory damages if the public officials "failed to perform their legal duties under R.C. 149.43(B) to provide access to those records." Even though prison officials had failed to provide access to the records for more than ten days, which would have resulted in the maximum fine of $1,000, the court of appeals denied Dehler the statutory damages because Dehler had another mandamus action pending in an unrelated public records request. Dehler appealed.
The Ohio Supreme Court held that the court of appeals was right, but for the wrong reasons. Stating that prison officials were not required to provide inspection of public records if it might unreasonably interfere with the discharge of their duties, the Supreme Court held that Dehler should have prepaid the copying fees and his failure to do so relieved prison officials of liability for the statutory damages. The Supreme Court also noted that "R.C. 149.43(C)(1) did not permit stacking of statutory damages based on what is essentially the same records request." Therefore, it affirmed the judgment of the court of appeals denying the award. Justice Brown filed a dissenting opinion. See: State ex rel. Dehler v. Kelly, S.Ct. Ohio, No. 2010-Ohio-5724.
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Related legal case
State ex rel. Dehler v. Kelly
| Year | 2010 |
|---|---|
| Cite | S.Ct. Ohio, No. 2010-Ohio-5724 |
| Level | State Supreme Court |
| Injunction Status | N/A |