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Request is Overly Broad When Seeking Records That Do Not Exist

In the case State ex rel. Dissell v. Cleveland, 2021-Ohio-2937, the Eighth District Court of Appeals held that the city was proper in refusing to produce all records sought in a request that was overly broad and sought records that did not exist.

Here, the requester sought emails sent to a dedicated means of contact for the city during a specific time period and the call log for the same contact. The city argued that a time period was not a specific request and that a call log for the contact did not exist. The Court of Appeals agreed.

The Court reasoned that the request was not limited by subject and it sought duplicative records and/or records that did not exist. As such, the Court held that the city was not required to produce such documents.

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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