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100,000 Emails May Be Too Much for a Records Request

In the case of Warchol v. Superintendent of Washington Local School Dist., 2022-Ohio-3140, a special master held that a request for all documents, email, and correspondence regarding COVID-19, unspecified certifications, school funding, and HVAC system maintenance without a specified time period were ambiguous and overbroad and, therefore, the superintendent was not required to supply any record under R.C. 149.43.

In this case, the requester argued that the requests were not ambiguous and overbroad. In response, the superintendent argued that the request was so broad that more than 100,000 emails applied and, even after a narrowed request was submitted, tens of thousands of pages applied. The appellate court agreed with the superintendent.

In support of its decision, the appellate court explained that:

As used here, the demand for records “regarding” or “in regards to” the listed broad topics is independently sufficient to render the request ambiguous and overly broad. Indeed, without sufficient specificity as to the particular records sought a court cannot issue an order for production of specific responsive records or determine and enforce non-compliance therewith.

2022-Ohio-3140 at ¶ 20.

To read this case, click here.

Authors: Matthew John Markling and the McGown & Markling Team.


Note: This blog entry does not constitute – nor does it contain – legal advice. Legal jurisprudence is like the always-changing Midwestern weather. As a result, this single blog entry cannot substitute for consultation with a McGown & Markling attorney. If legal advice is needed with respect to a specific factual situation, please feel free to contact a McGown & Markling attorney.

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