The State Ex Rel. Martin v. Greene., 129 N.E.3d 419

Relator Andre Martin, an inmate at Southern Ohio Correctional Facility, sent a public-records request (via prison "kite") around Dec 15, 2017 seeking his inmate bank-account records for November and December 2017.
Administrative assistant Larry Greene acknowledged receipt and forwarded the request to the cashier’s office but made no further response initially.
Martin filed a mandamus complaint on Jan 16, 2018; the facility provided the requested records eight days later.
Greene moved to dismiss for procedural defects; the court denied that motion and issued an alternative writ and evidentiary schedule.
Martin later sought to have the affidavit and exhibits attached to his complaint treated as evidence; he also sought statutory damages and court costs under Ohio’s Public Records Act.
The court found Martin had received the records, denied the mandamus writ as moot, and denied statutory damages and costs on the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus should issue to compel production of records	Martin argued Greene failed to produce requested records, entitling him to mandamus	Greene produced the records after the complaint was filed; production moots mandamus	Denied as moot — mandamus will not compel an act already performed
Availability of statutory damages under R.C. 149.43(C)(2)	Martin sought statutory damages for denial/delay of records	Greene argued damages require proof request was delivered by hand or certified mail	Denied — Martin produced no evidence of hand or certified-mail delivery, so damages unavailable
Award of court costs under Public Records Act	Martin sought court costs claiming delay and production after suit	Greene argued no court order was required and no bad faith occurred in voluntary production	Denied — no court order, and evidence did not show bad faith by the agency
Consideration of affidavit/exhibits attached to complaint as evidence	Martin asked court to accept complaint attachments as substantive evidence	Greene opposed; court set schedule for evidence and briefs	Motion denied as moot — attachments do not alter mootness or support damages/costs claims

State ex rel. Martin v. Buchanan, 152 Ohio St.3d 68 (2017) (mandamus will not compel acts already performed)
State ex rel. Love v. O’Donnell, 150 Ohio St.3d 378 (2017) (elements required to obtain writ of mandamus)
State ex rel. Toledo Blade Co. v. Seneca Cty. Bd. of Commrs., 120 Ohio St.3d 372 (2008) (public-records mandamus generally becomes moot when records are provided)
State ex rel. Eubank v. McDonald, 135 Ohio St.3d 186 (2013) (mandamus will not lie to compel an act already performed)