The Ohio Court of Appeals has affirmed the dismissal of a case brought by Isaiah Hunter-Bey against the City of Cleveland Law Department. Hunter-Bey claimed the city failed to respond to his public records request, but the court found he did not follow the proper legal procedures. This ruling impacts how public records requests are handled in Ohio and emphasizes the importance of adhering to statutory requirements.
Hunter-Bey filed his petition on August 8, 2025, after he alleged that the City of Cleveland did not comply with his public records request submitted on June 18, 2025. His request sought emergency communication records related to 911 calls made between June 7 and June 15, 2025. He specifically asked for various records, including computer-aided dispatch logs and audio recordings of 911 calls.
In his petition, Hunter-Bey asserted that he had hand-delivered the public records request and later reinforced it with a voicemail. He claimed that 50 days had passed without any response from the City, exceeding the time frame allowed under Ohio’s Public Records Act. He sought an order from the court to compel the City to comply with his request and also requested damages and attorney fees.
After Hunter-Bey filed his petition, he submitted several additional motions, including a request for statutory damages and a motion for reasonable accommodations under the Americans with Disabilities Act (ADA). However, the City responded with a motion to dismiss, arguing that the case was moot because they provided the requested records shortly after being served.
The City also contended that Hunter-Bey did not follow the necessary steps outlined in Ohio law. Specifically, R.C. 149.43(C)(1) requires that a person must serve a complaint on the public office and allow three days for the office to address the issue before filing a mandamus action. The trial court agreed with the City, dismissing Hunter-Bey’s petition on September 24, 2025, for failing to comply with these requirements.
In his appeal, Hunter-Bey raised three main arguments. He claimed that the trial court erred by not ruling on his pending motions before dismissing the case. He also argued that the court should not have entered a final judgment while multiple motions were still pending. Lastly, he contended that the court abused its discretion by dismissing his petition despite what he described as clear violations of the law by the City.
The Ohio Court of Appeals, led by Judge Mary J. Boyle, reviewed the case and found that Hunter-Bey's arguments were not persuasive. The court noted that even though Hunter-Bey was representing himself, he was still required to adhere to the same legal standards as any other litigant. The court emphasized that there is no legal requirement for a trial court to rule on every pending motion before making a decision on a case.
In addressing Hunter-Bey's claim about the public records request, the court reiterated the importance of following the statutory procedures outlined in R.C. 149.43(C)(1). The law requires that a person must file a complaint with the public office and allow three days for the office to respond before pursuing legal action. The court found that Hunter-Bey did not follow these steps, which justified the trial court's dismissal of his petition.
Ultimately, the Ohio Court of Appeals affirmed the trial court's decision, stating, "After accepting all factual allegations in the petition as true and drawing all reasonable inferences in favor of Hunter-Bey, we find that it is apparent from the four corners of the petition that he did not follow the procedure set forth in R.C. 149.43(C)(1)." The ruling underscores the necessity for individuals to understand and comply with legal procedures when making public records requests.
This decision may have broader implications for how public records requests are handled in Ohio, as it reinforces the requirement for individuals to adhere to statutory protocols. The ruling serves as a reminder that failure to follow these procedures can result in the dismissal of cases, even if the underlying request for information is legitimate.
Looking ahead, Hunter-Bey may have the option to appeal the ruling further, but details about any potential next steps were not available in the court filing. The case highlights the ongoing challenges individuals may face when navigating public records laws and the importance of understanding the legal framework surrounding such requests.