In a recent ruling, the Ohio Court of Claims decided in favor of the Perry County Agriculture Society, denying a public records request made by Joe B. Shaner. The court found that the society had adequately responded to the request and that Shaner would be responsible for the costs of the case. This decision has implications for how public records requests are handled in Ohio.

The case, titled Shaner v. Perry County Agriculture Society, was filed under docket number 2026-00028PQ. The court's ruling was issued by Special Master Sarah Pierce on June 22, 2026. The outcome is significant for individuals seeking access to public records and the obligations of public offices in Ohio.

Background

Joe B. Shaner, the requester in this case, submitted a public records request to the Perry County Agriculture Society on October 29, 2025. He sought various documents, including treasurer’s reports, meeting minutes, audit records, and contracts related to events such as the Perry County Fair Board and the Perry County Gun Bash. The request covered a period from October 31, 2022, to October 31, 2025.

In response, the Agricultural Society provided Shaner with approximately 683 pages of documents, although some of these records were redacted to comply with state laws regarding public records. Following the response, Shaner filed a complaint on January 9, 2026, claiming that the society had not fully complied with his request and that further records existed.

The case was referred to mediation, but when that did not resolve the dispute, both parties were instructed to file evidence and legal memoranda. The matter was then ready for a decision by the court.

The Ruling

The court ruled in favor of the Perry County Agriculture Society, stating that the production of the requested records rendered the public records claim moot. The court noted, “Providing requested records generally renders a public-records claim moot.” It concluded that since the society had produced the requested records, Shaner was not entitled to any further production.

Regarding the existence of additional records, the court found that the Agricultural Society was not required to provide records that were in the possession of another government agency, specifically the Auditor of State. The ruling stated, “A public office does not have a clear legal duty to furnish records that are not in its possession or control.”

The court also addressed Shaner’s claims about redactions made to the documents provided. It upheld the Agricultural Society’s decision to redact certain information, affirming that the redactions were appropriate and did not violate the Public Records Act.

Impact

This ruling has important implications for public records requests in Ohio. It clarifies that public offices are not obligated to retrieve records from other agencies and that the production of records can moot claims for further disclosure. Additionally, it reinforces the idea that redactions made to protect sensitive information are permissible under the law.

The decision also highlights the responsibilities of requesters to provide evidence when claiming that further records exist. The court emphasized that the burden lies with the requester to demonstrate that the records they seek are indeed in the possession of the public office.

What's Next

Shaner has the option to file a written objection to the court's recommendation within seven business days of receiving it. If he chooses to do so, it could lead to further proceedings in the case. The outcome of this case may also influence future public records requests and the practices of public offices in Ohio.