Rhodes v. City of New Philadelphia, 129 Ohio St. 3d 304

Rhodes, a public-records requester, sought reel-to-reel police dispatch tapes (1975–1995) from several Ohio entities; most tapes had been disposed.
New Philadelphia destroyed the tapes 30 days after recording, violating RC 149.351(A).
Rhodes filed a civil-forfeiture claim under RC 149.351(B), alleging he was aggrieved and entitled a $1,000 forfeiture for each violation.
Trial evidence focused on the number of violations and whether Rhodes was aggrieved; a jury found he was not aggrieved.
The Fifth District reversed, holding aggrievement is not a factual jury issue and that Rhodes was aggrieved as a matter of law.
The Ohio Supreme Court reversed, holding aggrieved requires infringement of the requester’s legal rights to access records; Rhodes did not actually want the records, only forfeiture for their destruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Meaning of 'aggrieved' under RC 149.351(B)	Rhodes is aggrieved any time a records request is denied.	Aggrieved requires infringement of legal rights; not aggrieved if the requester seeks forfeiture.	Aggrieved requires rights infringement; Rhodes not aggrieved.

Kish v. Akron, 109 Ohio St.3d 162 (2006-Ohio-1244) (public-records purpose to monitor government; requester protected regardless of motive)
State ex rel. Morgan v. New Lexington, 112 Ohio St.3d 33 (2006-Ohio-6365) (any person right to access records; motive irrelevant)
Fant v. Enright, 66 Ohio St.3d 186 (1993-Ohio-188) (public-records requests cannot require requester identity or use; any person)
Beacon Journal Pub. Co. v. Waters, 67 Ohio St.3d 321 (1993-Ohio-322) (public records access as substantive right to inspect/copy)