State ex rel. Zidonis v. Columbus State Community College, 133 Ohio St. 3d 122

Zidonis, a former Columbus State employee, sought access to complaint files, litigation files, and e-mails under R.C.149.43; the mandamus action followed when access was denied or not clearly provided.
Columbus State promptly produced nearly 400 pages of records, including Zidonis’s personnel file and others, and supplied its records-retention schedule.
Zidonis’ June–August 2010 request for all e-mails between her and a supervisor was deemed overly broad; the college attempted to narrow and discuss the scope.
Requests for complaint and litigation files were treated as overbroad due to unbounded categories and timeframes; retention policy contemplated six years from last activity.
Columbus State eventually created a search program and produced redacted e-mails, but the court denied the mandamus relief, affirming that the requests were not sufficiently definite or reasonable under the Public Records Act.
The Supreme Court affirmed, holding that the relator failed to prove, by clear and convincing evidence, a violation of R.C.149.43, and that the agency complied with the relevant provisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the complaint and litigation-file requests were overbroad.	Zidonis asserted overbreadth, seeking broad categories across six years.	Columbus State argued categories and timeframe were too vague and not reasonably identifiable.	Yes; the requests were overbroad and not sufficiently specific.
Whether the e-mail request was subject to a duty to organize for retrieval by sender/recipient under RC 149.43(B)(2).	Zidonis claimed the statute requires organizing e-mails for retrieval by sender/recipient.	The statute does not require such retrieval-system organization.	No; statute does not obligate the agency to retrieve by sender/recipient.
Whether Columbus State violated RC 149.43(B)(2) by not informing the requester how records are maintained to assist narrowing requests.	Zidonis contends the agency failed to inform her how records are kept to aid revisions.	CSCS engaged in discussions and offered guidance to narrow the request; cooperation allowed.	No; the agency properly informed and facilitated narrowing as allowed.
Whether mandamus was the appropriate remedy and whether the court properly denied the writ given the agency’s conduct.	Zidonis sought mandamus to compel access and damages/fees.	The requested relief was improper given overbreadth and lack of clear violations.	Yes; mandamus denied; court affirmed denial of extraordinary relief.

State ex rel. Glasgow v. Jones, 119 Ohio St.3d 391 (2008-Ohio-4788) (overbroad request for broad categories of records)
State ex rel. Dehler v. Spatny, 127 Ohio St.3d 312 (2010-Ohio-5711) (overbroad seven-year record request)
State ex rel. Morgan v. New Lexington, 112 Ohio St.3d 33 (2006-Ohio-6365) (records request must identify records with reasonable clarity)
State ex rel. Vaughn v. Money, 104 Ohio St.3d 322 (2004-Ohio-6561) (mandamus not to obtain what relator already has)
State ex rel. Patton v. Rhodes, 129 Ohio St.3d 182 (2011-Ohio-3093) (legislative-duty creation in mandamus context)