2017 Ohio 7810
Ohio Ct. App.2017Background
- Relator Ronald Bloodworth, an inmate at Lebanon Correctional Institution and a declared vexatious litigator, filed a mandamus petition alleging nonproduction of public records by Warden Bobby Bogan (and administrative assistant/public information officer Chae Harris) and ODRC staff.
- The petition consolidated eight kite-based public-records requests (Oct 2015–Feb 2016) seeking documents about WCI library/LexisNexis equipment, mail-chain procedures, legal-mail logs, RIB (rules infraction board) records, and related materials.
- Respondents produced multiple documents (e.g., library handbook, email exchanges, redacted legal-mail logs, conduct report, disposition) and explained denials where records did not exist or were exempt.
- Respondents redacted inmate-identifying information from logs based on R.C. provisions limiting disclosure of inmate records; relator objected to redactions and to some denials as untimely or incomplete.
- The court found respondents generally responded appropriately: records were produced when they existed and were public, otherwise legitimately withheld; relator also failed to exhaust administrative remedies under R.C. 2969.26(A).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Were requested documents produced as required by the Public Records Act? | Bloodworth: respondents failed to produce requested public records. | Respondents: they produced available public records, denied requests when records did not exist or were not public. | Court: respondents complied when records existed; petition lacks merit. |
| Are redactions of legal-mail/ledger logs permissible? | Bloodworth: demanded unredacted outgoing legal-mail logs. | Respondents: redactions necessary to protect other inmates' nonpublic information. | Court: redactions appropriate under inmate-records exceptions. |
| Were some requests denied because records did not exist? | Bloodworth: contends requested schedules/logs exist and were withheld. | Respondents: certain logs or policies do not exist, so nothing to produce. | Court: agency not required to produce non-existent records. |
| Must relator exhaust prison grievance/administrative remedies before filing? | Bloodworth: filed mandamus without showing exhaustion. | Respondents: R.C. 2969.26(A) requires exhaustion for actions affecting institutional life. | Court: relator failed to exhaust; failure is independent ground to dismiss. |
Key Cases Cited
- Physicians Commt. for Responsible Medicine v. Ohio State Univ. Bd. of Trustees, 108 Ohio St.3d 288 (2006) (custodian bears burden to prove applicability of exception to disclosure under Public Records Act)
- State ex rel. Harris v. Rhodes, 54 Ohio St.2d 41 (1978) (records on prisoners kept by corrections department are not public records)