The Ohio Court of Claims ruled that the Ohio Department of Rehabilitation and Correction (ODRC) complied with a previous court order regarding records requested by Lachanda Gales. This decision, filed under case number 2025-00893PQ, is significant for individuals seeking access to public records, particularly in cases involving incarceration.
Lachanda Gales initiated her complaint against ODRC on October 27, 2025. She sought records related to J.C. Sanders, an inmate whose custody she questioned. Gales filed her request under Ohio Revised Code 2743.75, which allows individuals to seek public records. The dispute arose when ODRC did not initially provide the records Gales requested, prompting her to file a motion for enforcement and sanctions.
The case moved quickly through the court system. On December 3, 2025, the special master assigned to the case bypassed mediation and instructed ODRC to respond to Gales's request. ODRC filed a motion to dismiss on December 17, 2025, but the special master recommended denying that motion and ordered ODRC to produce the requested records within 30 days. The court adopted this recommendation on February 2, 2026.
After Gales filed a motion on March 5, 2026, claiming that ODRC had not complied with the court's order, ODRC responded on March 12, stating that it had emailed the requested records to Gales. However, Gales contended that the records provided were not what she had requested, leading to further complications in the case.
The court's ruling, delivered by Special Master Robert Van Schoyck, concluded that ODRC had indeed complied with the February 2 judgment. The opinion noted, "ODRC produced responsive records in accordance with the court’s February 2, 2026 judgment entry and is reimbursing Gales’s filing fee as ordered in the February 2, 2026 judgment entry." This statement highlights the court's finding that ODRC fulfilled its obligations regarding the records request.
Gales had requested various documents, including any reinstatement orders or court judgments related to Sanders's imprisonment, as well as all documentation justifying his custody. The special master determined that ODRC had produced all records in its possession that were responsive to Gales's request. Gales argued that the records were insufficient, claiming that only a small portion of the documents were relevant to her inquiry.
In response to Gales's claims, ODRC maintained that the records provided were comprehensive and directly related to her request. The court noted that Gales had the burden of proving that additional records existed and were kept by ODRC, a burden she did not meet. The ruling emphasized that a public office is not required to provide records it does not possess.
The ruling has implications for future public records requests, particularly in cases involving correctional facilities. It reinforces the idea that public agencies must only provide records that are in their possession and that requesters must clearly demonstrate the existence of any additional records they believe should have been provided.
Looking ahead, Gales has the option to file an objection to the special master's recommendation within seven business days. This could lead to further litigation if she chooses to pursue the matter. The court's decision does not preclude Gales from seeking additional records in the future, but it does set a precedent for how such requests may be handled in Ohio.
The outcome of this case may influence how public records are requested and provided, particularly in the context of correctional institutions. It underscores the importance of clarity in requests and the responsibilities of public agencies in responding to those requests.