Background
Lionel Harris, an inmate at North Central Correctional Complex, sought mandamus relief under Ohio’s Public Records Act against a case manager, the warden’s assistant, and the prison operator. He made three electronic-kite requests: a July 2024 request for a paper copy of his master file; a December 2024 request concerning an authorization to screen his mail; and a January 2025 request for a contraband-control or individual-contraband slip concerning a withheld thumb drive.
The prison did not produce records in response to the master-file request. For the mail-related request, outside counsel said it could not identify a document by the title or number Harris supplied, offered identified mail policies upon advance payment of copying costs, and invited clarification. For the contraband-slip request, a staff member directed Harris to contact the mailroom, which would have handled the matter.
The Court’s Holding
The Supreme Court of Ohio granted mandamus in part. An internal ODRC policy barring incarcerated people from receiving copies of master-file documents could not override the statutory duties imposed by the Public Records Act. Because respondents did not establish that the entire file was exempt, they must produce responsive public records from Harris’s master file, with lawful redactions.
The court denied relief on the other two requests. Harris did not prove that additional responsive mail-screening records existed after counsel’s response and offer to provide identified policies at copying cost. And respondents complied with the Act as to the contraband-slip request when a non-records-custodian employee directed Harris to the department where the records could be located. The court awarded Harris $1,000 in statutory damages for the unfulfilled master-file request but denied court costs because he filed an indigency affidavit and thus incurred none.
Key Takeaways
- An agency policy cannot displace a public office’s statutory disclosure duties.
- Inmate master files may contain public records, though exempt information may be redacted.
- A requester cannot obtain mandamus for nonexistent records or where staff properly direct the request to the appropriate custodian.
Why It Matters
The decision reinforces that correctional institutions must evaluate requested master-file materials under the Public Records Act itself, rather than deny access wholesale under an internal inmate-access policy. It also confirms the limits of that duty when no responsive record is shown to exist or when a requester is directed to the proper source for records.