State ex rel. Griffin v. Sehlmeyer, 2022 Ohio 2189

Relator Mark Griffin, an inmate at Toledo Correctional Institution (TCI), submitted a May 8, 2021 public-records request via TCI’s electronic "kite" seeking "documented records" of state or federal funding approved to TCI to fight COVID‑19, including amounts approved, amounts spent, documented purchases, and any balance remaining.
TCI records custodian Sonrisa Sehlmeyer acknowledged receipt automatically and then closed the request without providing substantive records before this suit; Griffin filed an original-action mandamus under R.C. 149.43 seeking disclosure and statutory damages.
Sehlmeyer averred she lacks direct access to ODRC-maintained records, denied that responsive records exist at TCI, and (confusingly) referenced an earlier July 3, 2020 request and response about CRF funds to ODRC.
The court treated Griffin’s attached kite and affidavit as evidence that he submitted the May 8, 2021 request and granted an alternative writ for briefing and evidence.
Central legal dispute: whether Griffin’s request sought identifiable public records (a proper records request) or instead sought information that would require the custodian to search and create a response (an improper request under R.C. 149.43).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Griffin’s submission was a proper public‑records request under R.C. 149.43	Griffin argued he requested "documented records" showing amounts approved, spent, purchases, and balances—i.e., existing records showing COVID‑19 funding to TCI	Sehlmeyer argued the submission sought information (amounts/balances) rather than identified records and would require a search/create new records, so it was not a proper request	Court held the request sought information, not identifiable records, and therefore was not a proper records request under R.C. 149.43 (writ denied)
Entitlement to statutory damages under R.C. 149.43(C)(2)	Griffin sought statutory damages for alleged failure to timely disclose responsive records	Sehlmeyer argued statutory damages unavailable because the request did not fairly describe public records (it sought information) and thus no violation occurred	Court held Griffin not entitled to statutory damages because his request failed to fairly describe identifiable public records; no statutory violation proven

State ex rel. Morgan v. New Lexington, 857 N.E.2d 1208 (Ohio 2006) (requests that require creating new records or searching for specified content are improper under the Public Records Act)
State ex rel. Shaughnessy v. Cleveland, 76 N.E.3d 1171 (Ohio 2016) (records requests that force the custodian to identify responsive documents by content are improper)
State ex rel. Griffin v. Sehlmeyer, 179 N.E.3d 60 (Ohio 2021) (prior Griffin decision addressing inmate use of electronic kite system and public‑records issues)
State ex rel. Griffin v. Sehlmeyer, 185 N.E.3d 58 (Ohio 2021) (subsequent Griffin decision denying writ when request sought information rather than records)
State ex rel. Armatas v. Plain Twp. Bd. of Trustees, 170 N.E.3d 19 (Ohio 2021) (statutory‑damages entitlement requires a written request that fairly describes the records and a court finding of noncompliance)
State ex rel. McCaffrey v. Mahoning Cty. Prosecutor’s Office, 976 N.E.2d 877 (Ohio 2012) (relator bears clear‑and‑convincing burden in public‑records mandamus)