In the case Patrick v. N. Olmsted, 2021-Ohio-2650, the Ohio Court of Claims held a public records request was not specific enough in its request and that there was no evidence to substantiate the claim that the city failed to supply additional responsive documents.
Here, the requester argued that the city denied them access to public records by withholding responsive documents. To the contrary, the city argued that a secondary production to the requestor included all requested records and that there were no remaining documents to be produced. The Court agreed.
The Court held that the city properly produced all additional records in its secondary production and as such, the Court dismissed the two requests that did not refer to specific records that had not yet been produced.
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.