State ex rel. Suggs v. McConahay, 2022 Ohio 2147

Inmate Anthony Suggs requested copies of four electronic "kites" (inmate-to-staff communications) on July 31, 2021, under Ohio’s Public Records Act, R.C. 149.43, to support federal-court filings.
The Mansfield Correctional Institution warden initially acknowledged the request but did not deliver the records promptly.
Suggs filed an original mandamus action in the Ohio Supreme Court on August 25, 2021; the court issued an alternative writ.
The warden produced the responsive kites to Suggs on September 8, 2021 (after the mandamus filing) and submitted affidavits and copies of the kites as evidence.
The warden argued the kites were exempt as "records of inmates" under R.C. 5120.21(F) and that production was a courtesy rather than a statutory disclosure; Suggs sought statutory damages for the delay.
The court denied the mandamus claim as moot (records provided) but awarded Suggs $900 in statutory damages for nine business days of noncompliance beginning on the date the action was filed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus is appropriate when records were produced after suit	Suggs sought writ to compel disclosure	Warden said records were produced (so no relief due)	Mandamus denied as moot because records were produced and production unrebutted
Whether inmate kites are public records under R.C. 149.43	Kites are public records subject to disclosure	Kites are exempt as "records of inmates" under R.C. 5120.21(F)	Kites are public records; the warden’s categorical exemption argument rejected (following court precedent)
Whether electronic submission via the prison kite system satisfies R.C. 149.43(C)(2) for statutory damages eligibility	Suggs transmitted request electronically and is eligible	Warden disputed transmission proof	Electronic kite qualifies as an "electronic submission," so Suggs is eligible for statutory damages
Calculation and award of statutory damages under R.C. 149.43(C)(2)	Damages accrue from date of suit until compliance ($100 per business day, up to $1,000)	Warden argued no statutory liability (records exempt / courtesy)	Awarded $900 (nine business days from filing to production)

State ex rel. Martin v. Greene, 156 Ohio St.3d 482, 2019-Ohio-1827, 129 N.E.3d 419 (recognizing a kite as an inmate-staff communication)
State ex rel. Physicians Commt. for Responsible Medicine v. Ohio State Univ. Bd. of Trustees, 108 Ohio St.3d 288, 2006-Ohio-903, 843 N.E.2d 174 (mandamus is proper to enforce R.C. 149.43)
State ex rel. Striker v. Smith, 129 Ohio St.3d 168, 2011-Ohio-2878, 950 N.E.2d 952 (public-records mandamus generally becomes moot when records are produced)
State ex rel. Kesterson v. Kent State Univ., 156 Ohio St.3d 13, 2018-Ohio-5108, 123 N.E.3d 887 (statutory damages may be awarded even if mandamus relief is moot)
State ex rel. Griffin v. Sehlmeyer, 165 Ohio St.3d 315, 2021-Ohio-1419, 179 N.E.3d 60 (electronic submission via prison systems can satisfy statutory "electronic submission" requirement)
State ex rel. Hackworth v. Hughes, 97 Ohio St.3d 110, 2002-Ohio-5334, 776 N.E.2d 1050 (verification requirement for original actions and effect of curative admissions)