State ex rel. Brown v. Columbiana County Jail, 2025-Ohio-5280

Case Information

Court: Supreme Court of Ohio
Date: 2025-11-26
Citation: 2025-Ohio-5280
Read the Opinion

Summary

Summary: This mandamus action addressed whether an incarcerated individual was entitled to statutory damages and contempt sanctions after asserting that the Columbiana County Sheriff’s Office failed to produce certain public records. The Supreme Court of Ohio held that the relator failed to prove proper service of his request and that the sheriff complied with the limited writ issued in a prior decision.

Key Holdings

• A relator must show by clear and convincing evidence that a public records request was transmitted via hand delivery certified mail or electronic submission to be eligible for statutory damages
• A public office is not required to respond to overly broad or vague public records requests
• The sheriff satisfied the court’s limited writ by seeking and forwarding documents from third-party private jail administrators
• A private entity’s failure to produce documents does not constitute contempt by the public official who requested them
• Requests submitted by a nonattorney without documentation of agency authority do not entitle the relator to statutory damages

More Information

This case originated from an incarcerated individual’s attempt to obtain records from the Columbiana County Sheriff’s Office relating to jail operations, personnel, and policies. After failing to receive the requested documents, he filed for a writ of mandamus, which was partially granted by the court in a prior ruling. The sheriff was ordered to either produce the records or certify their nonexistence, including records held by private contractors managing the jail.

The relator later filed for contempt and statutory damages, asserting noncompliance. However, the court found that the relator failed to show that his requests had been validly transmitted through acceptable legal channels—his attempts by hand delivery and certified mail were unsuccessful, and the email submission by a third party lacked adequate documentation of agency authority.

Procedurally, the court evaluated compliance with its prior limited writ and determined that the sheriff had satisfied the court’s directives by contacting the third-party contractors and forwarding their responses to the relator. It emphasized that any lack of records was due to the contractors’ limited responses, not the sheriff’s resistance or disobedience.

Legally, the case reinforces that public offices must respond to clear and properly transmitted public records requests, and that requesters bear the burden of demonstrating compliance with statutory procedures. It also clarifies that a private entity’s noncompliance cannot result in contempt findings against a public official who acted in good faith and within the bounds of the court’s order.