Background
Corrionne Lawrence, an inmate at Toledo Correctional Institution, brought a mandamus action seeking records from the Ohio Department of Rehabilitation and Correction’s Operation Support Center, along with statutory damages and court costs under Ohio’s Public Records Act.
In an earlier opinion, the Supreme Court of Ohio ordered ODRC either to provide Lawrence’s master file or to certify that it did not possess the file. The court denied relief concerning Lawrence’s other requests and deferred deciding whether he was entitled to statutory damages for the master file. ODRC subsequently produced the file in response to the limited writ.
The Court’s Holding
The court awarded Lawrence $1,000 in statutory damages. Because ODRC produced the master file after being ordered to do so and did not dispute possessing it when Lawrence requested it, the court concluded that ODRC had failed to satisfy its obligation to produce the record in response to his public-records request.
Lawrence qualified for statutory damages because he submitted his request through an electronic kite, which constituted an electronic submission under R.C. 149.43(C)(2). Damages accrued at $100 for each business day of noncompliance beginning when Lawrence filed the mandamus action, capped at $1,000; ODRC did not comply until more than ten business days later. Although current Ohio law prohibits inmates from recovering such damages, the earlier statutory version governing this case contained no such prohibition.
Key Takeaways
- A public office’s production of a record in response to a limited writ, without disputing that it possessed the record when requested, can establish a prior violation of the Public Records Act.
- An inmate’s electronic kite can qualify as an electronic submission for purposes of statutory damages under R.C. 149.43(C)(2).
- Under the statute applicable to this case, damages accrued at $100 per business day after the mandamus filing and reached the $1,000 statutory maximum.
Why It Matters
The decision confirms that belated production following a court order does not eliminate statutory-damages exposure when the public office possessed the requested record but failed to produce it in response to a qualifying request.
The result also turns on timing: Lawrence could recover because the 2023 version of the Public Records Act governed his case, while the amendment effective April 9, 2025, bars inmates from recovering statutory damages.