2025 Ohio 3150
Ohio Ct. App.2025Background
- Pro se plaintiff Lavar Martin sought personnel and employment records from Accel Schools Ohio (a private Delaware LLC managing Ohio community schools) after public-records requests in May–June 2024; Accel responded there were no public records.
- Martin filed a public-records-access complaint in the Ohio Court of Claims under R.C. 149.43(B); the Court of Claims assigned a special master and ordered in-camera production of unredacted documents.
- Accel objected, arguing the Court of Claims lacked subject-matter jurisdiction over private entities and disputed that it was a “public office” or the functional equivalent thereof; Accel moved to dismiss under Civ.R. 12(B)(1) and (6).
- The special master and the Court of Claims denied dismissal, found Accel functionally equivalent to the community schools (and a quasi-agent), and ordered production; Accel timely appealed.
- The Eighth District reversed the Court of Claims on jurisdictional grounds, holding R.C. 2743.03(A)(3)(b) did not expressly expand the Court of Claims’ jurisdiction to private entities, and therefore the Court of Claims lacked subject-matter jurisdiction to hear Martin’s complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Court of Claims has subject-matter jurisdiction over a public-records complaint against a private entity under R.C. 2743.03(A)(3)(b) | Court of Claims now has exclusive jurisdiction over public-records claims regardless of whether the records-holder is state or political subdivision | R.C. 2743.03(A)(3)(b) does not expressly grant jurisdiction over private entities; Court of Claims’ jurisdiction remains limited to the state and political subdivisions | Reversed: Court of Claims lacks subject-matter jurisdiction because the statute did not expressly expand jurisdiction to private entities |
| Whether Accel is the “functional equivalent” of the community schools it manages | Accel’s management duties and agreements make it functionally equivalent, so its documents are public records | Accel is a private LLC and not functionally equivalent to public offices | Trial court found functional equivalence; appellate court did not reach merits and reversed on jurisdictional grounds |
| Whether Accel is a “quasi‑agent” of the community schools for personnel records | Quasi‑agency makes Accel’s records subject to the Public Records Act | Accel denies quasi‑agency and contends records are private | Trial court found quasi‑agency; appellate court declined to decide after finding lack of jurisdiction |
Key Cases Cited
- Morrison v. Steiner, 32 Ohio St.2d 86 (1972) (defining subject‑matter jurisdiction concept)
- Southgate Dev. Corp. v. Columbia Gas Transm. Corp., 48 Ohio St.2d 211 (1976) (trial court may consider materials beyond complaint when resolving jurisdiction)
- Avco Fin. Servs. Loan, Inc. v. Hale, 36 Ohio App.3d 65 (10th Dist. 1987) (same rule on jurisdictional review)
- Symmes Twp. Bd. of Trustees v. Smyth, 87 Ohio St.3d 549 (2000) (statutory construction principles: plain language controls)
- State ex rel. A. Bentley & Sons Co. v. Pierce, 96 Ohio St. 44 (1917) (doubt about statutory grants of power resolved against expansion)
- State ex rel. Bush v. Spurlock, 42 Ohio St.3d 77 (1989) (whether a cognizable cause of action exists for forum consideration)