State ex rel. Carr v. London Correctional Institution, 144 Ohio St. 3d 211

Relator James M. Carr Sr., an inmate at London Correctional Institution (LCI), requested internal memos/emails from Chaplain Cahill to the prison mailroom in March–April 2012; some requests were denied as "ambiguous, overbroad, and unduly burdensome."
Carr delivered written requests by hand to an institutional inspector for transmission to the warden’s administrative assistant (Vickey Justus), who was responsible for public-records responses.
LCI eventually produced a January 30, 2012 memo only when filing a motion for summary judgment in the court of appeals, about a year after Carr’s initial request.
Carr filed a mandamus action in the Twelfth District to compel production of the withheld records and sought statutory damages and costs under Ohio’s Public Records Act (R.C. 149.43).
The Twelfth District denied relief, concluding Carr’s March 5 request was ambiguous and his March 15 and April 10 requests were overbroad; it also denied statutory damages. The Ohio Supreme Court reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Carr’s R.C. 2969.25(A) affidavit complied with statute	Affidavit listed prior actions sufficiently; no omitted civil cases shown	LCI argued affidavit was deficient in form and detail	Court: affidavit met statutory requirements despite not being a model; sufficient information present
Whether March 5, 2012 request was ambiguous (invalid)	Identified author, recipient, and approximate timeframe; witnesses verified existence	LCI: request required research to identify the record	Court: not ambiguous—request fairly described a particular existing document; denial was erroneous
Whether March 15 and April 10, 2012 requests were overbroad	Requests sought communications from one named sender to one office over defined period—reasonably narrow	LCI: multiple records over time made requests overbroad and burdensome	Court: requests were not overbroad; denial was erroneous
Whether statutory damages and costs should be awarded under R.C. 149.43(C)	Carr hand-delivered written requests and was entitled to damages and costs because LCI failed to timely produce records	LCI: production of one memo later cured violation; denial reasonable; public-policy concerns could reduce damages	Court: delivery to prison official satisfied hand-delivery; LCI’s withholding was unreasonable; awarded maximum statutory damages ($1,000) and court costs; remanded to calculate costs

State ex rel. Physicians Comm. for Responsible Medicine v. Ohio State Univ. Bd. of Trustees, 108 Ohio St.3d 288 (2006) (mandamus is proper remedy to enforce Ohio Public Records Act)
State ex rel. Rocker v. Guernsey Cty. Sheriff’s Office, 126 Ohio St.3d 224 (2010) (PRA construed liberally in favor of disclosure)
State ex rel. Doner v. Zody, 130 Ohio St.3d 446 (2011) (relator must prove entitlement to extraordinary relief by clear and convincing evidence)
State ex rel. Morgan v. New Lexington, 112 Ohio St.3d 33 (2006) (definition of improper "research" and that perfect specificity in request is not required)
State ex rel. Cater v. N. Olmsted, 69 Ohio St.3d 315 (1994) (failure to specify date does not automatically invalidate a public-records request)
State ex rel. Glasgow v. Jones, 119 Ohio St.3d 391 (2008) (overbroad requests may include a public official’s entire body of communications over long periods)
State ex rel. Dillery v. Icsman, 92 Ohio St.3d 312 (2001) (overbroad requests seeking any and all records referencing requester can be excessive)
State ex rel. Calvary v. Upper Arlington, 89 Ohio St.3d 229 (2000) (drafts can be public records; delays in providing drafts can support fee awards)
Gilbert v. Summit Cty., 104 Ohio St.3d 660 (2004) (requestor’s purpose for seeking records is irrelevant to entitlement)