State Ex Rel. Village of Richfield v. Laria
138 Ohio St. 3d 168
| Ohio | 2014Background
- Relator village of Richfield seeks records it claims are public under R.C. 149.43 but they are sealed by a visiting judge.
- Richfield sought unsealing of criminal records and moved for in camera inspection; judge denied unsealing with limited exceptions.
- Richfield filed mandamus arguing records were improperly sealed under R.C. 2953.52 or public records act; respondents refused production.
- Trial court denied Richfield’s unseal motion; Richfield then sought records under Public Records Act, which Respondents treated as non-existent.
- Court held Sup.R. 44–47 govern access to court records post-July 1, 2009; Richfield had an adequate remedy at law and mandamus cannot compel unsealing or substitute for appeal.
- Writ denied; discussion includes that mandamus cannot control judicial discretion and cannot replace an appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper vehicle for accessing court records | Richfield seeks under Sup.R. 44–47 (public records act not applicable) | Requests under Public Records Act were improper; records governed by Sup.R. 44–47 | Writ denied on lack of proper vehicle (Sup.R. 44–47) and adequate remedy at law |
| Adequate remedy at law for unsealing | Richfield had no adequate remedy if records improperly sealed | Richfield had an adequate remedy via appeal from sealing decision | Writ denied; adequate remedy at law exists via appeal |
| Mandamus as substitute for appeal or to control judicial discretion | Mandamus can compel unsealing | Mandamus cannot control discretion or substitute for appeal | Writ denied; cannot use mandamus to correct judicial discretion or bypass appeal |
Key Cases Cited
- State ex rel. Vindicator Printing Co. v. Wolff, 132 Ohio St.3d 481 (2012-Ohio-3328) (Sup.R. 44–47 control access to court records; adequate remedy at law not present here)
- State ex rel. Rashada v. Pianka, 112 Ohio St.3d 44 (2006-Ohio-6366) (mandamus cannot control judicial discretion or substitute for appeal)
- Daggett v. Gessaman, 34 Ohio St.2d 55 (1973) (mandamus not substitute for appeal; discretion rule)
- Overmeyer v. Walinski, 8 Ohio St.2d 23 (1966) (mandamus not substitute for appeal)