State ex rel. Dehler v. Spatny
127 Ohio St. 3d 312
Ohio2010Background
- Dehler sought a writ of mandamus to compel access to all quartermaster records of clothing and shoes at Trumbull Correctional Institution for more than seven years.
- The Court of Appeals denied the writ; the Ohio Supreme Court is reviewing that denial.
- Majority holds the requested records were overbroad and amounted to a complete duplication of records.
- Prison officials offered to provide copies at cost after prepayment, but Dehler refused to prepay.
- Prison officials argued that allowing inspection of the records could interfere with duties; Dehler’s inspection request was moot due to his transfer during the proceedings.
- The decision affirms the denial of the writ; the dissent would hold the request were sufficiently specific and not overbroad.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Dehler's request overbroad? | Dehler argues records are identifiable and not a full duplication. | State contends the request seeks a complete duplication of voluminous files. | Overbroad; request denied. |
| Is prepayment of copying costs proper to obtain records? | Dehler refused to prepay; argues right to inspect/copy without error. | Public records may be copied at cost with prepayment per R.C. 149.43(B)(1). | Copies may be provided at cost with prepayment; entitlement not established here. |
| May inspection of records be allowed when it risks interference with prison duties? | Inspections should be allowed as part of access to records. | Inspection could unreasonably interfere with duties; custodial concerns justify limits. | Inspection rights limited due to potential interference; moot on transfer. |
Key Cases Cited
- State ex rel. Glasgow v. Jones, 119 Ohio St.3d 391, 894 N.E.2d 686 (2008) (overbreadth limits on public-records requests; duplication concerns)
- State ex rel. Warren Newspapers, Inc. v. Hutson, 70 Ohio St.3d 619, 640 N.E.2d 174 (1994) (right to inspect subject to cost and custodian considerations)
- State ex rel. Call v. Fragale, 104 Ohio St.3d 276, 819 N.E.2d 294 (2004) (copies of public records must be made available at cost)
- State ex rel. Brown v. Lemmerman, 124 Ohio St.3d 296, 921 N.E.2d 1049 (2010) (consider facts and conditions after case filing in mandamus)
- State ex rel. Morgan v. New Lexington, 112 Ohio St.3d 33, 857 N.E.2d 1208 (2006) (reasonable identification of requested records; no automatic right to complete duplication)