Ohio Supreme Court Awards Prisoner $700 From Sheriff Who Failed to Comply with Public Records Request
by Douglas Ankney
On April 19, 2023, the Supreme Court of Ohio awarded prisoner Franklin Woods $700 in statutory damages against the Lawrence County Sheriff’s Office (LCSO) for failure to comply with a public-records request.
On August 1, 2022, while Woods was incarcerated at the Chillicothe Correctional Institution, he sent a letter by certified mail to LCSO that read: “I am writing to request a written retention schedule for: 1.) Incident reports 2.) Dispatch calls 3.) Dash cam footage 4.) Arrest reports 5.) Incoming - outgoing calls.” Maj. John Chapman responded to Woods by letter on August 26, 2022: “The letter you sent to the Lawrence County Sheriff’s Office is too vague to determine your requests.”
On November 4, 2022, Woods petitioned the state Supreme Court pro se for a writ of mandamus ordering the sheriff to produce the requested records. Woods also requested statutory damages. On November 22, 2022, the sheriff responded that the requested records had been sent on November 16, 2022, and he moved for judgment on the pleadings. On December 14, 2022, Woods notified the Court that he had received the requested records from the LCSO and renewed his request for statutory damages because of the months-long delay between his request and its fulfilment.
As the Court observed, “[t]he parties agree that the requested records have now been produced,” and “In general, a public-records mandamus case becomes moot when the public office provides the requested records,” as provided by State ex rel. Martin v. Greene, 129 N.E.3d 419 (Ohio 2019). The Court therefore granted the sheriff’s motion on the pleadings as to Woods’ mandamus claim, denying it as moot.
But as to Woods’ statutory-damages request, the Court opined: “R.C. 149.43(C)(2) provides that a requester shall be entitled to statutory damages if (1) he made a public-records request by one of the statutorily prescribed methods, (2) he made the request to the public office responsible for the requested records, (3) he fairly described the documents being requested, and (4) the public office failed to comply with its obligations in accordance with R.C. 149.43.”
As the Court noted, Woods satisfied the first two elements of this test because he “mailed his public-records request to the sheriff by certified mail, making him eligible for an award of damages.” Regarding the third element, LCSO argued that Woods’ request was vague and that Woods should have specified he was requesting the “Lawrence County Sheriff’s Office’s Record Retention Schedule.” But the Court rejected that argument, determining that Woods’ request “fairly described” the records, as required by the statute.
That left only his claim for damages, which the relevant statute provides in the amount of “$100 per day for each business day that the public office fails to comply with its obligations … with a maximum award of $1,000.” In the instant case, the Court calculated that the sheriff did not comply with his obligations under R.C. 149.43(B) for seven days. Accordingly, the Court awarded Woods $700 in statutory damages. See: State ex rel. Woods v. Lawrence Cty. Sheriff’s Off., 2023-Ohio-1241.
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Related legal case
State ex rel. Woods v. Lawrence Cty. Sheriff’s Off.
| Year | 2023 |
|---|---|
| Cite | 2023-Ohio-1241 |
| Level | State Supreme Court |
| Conclusion | Settlement |
| Damages | 700 |