The Ohio Court of Appeals recently ruled in favor of the City of Shaker Heights in a case involving a public records request made by Goffredo Di Fiore. The court affirmed the lower court's decision to dismiss Di Fiore's complaint, which claimed that the city unreasonably delayed providing him access to a traffic citation. This ruling clarifies the standards for what constitutes a reasonable delay in fulfilling public records requests under Ohio law.
Goffredo Di Fiore received a traffic ticket on January 23, 2025, for speeding in a 25 m.p.h. zone. Four days later, on January 27, Di Fiore visited the Shaker Heights Police Department to request a copy of the citation and additional records related to the incident. He claimed that although the citation was physically available, he was denied immediate access to it. Di Fiore filed a complaint in the Ohio Court of Claims in May 2025, alleging that the city violated the Ohio Public Records Act by failing to provide prompt access to the ticket.
The dispute centers around Di Fiore's assertion that the four-day delay in receiving the citation was unreasonable. He argued that since he was the subject of the record, the city should not have needed time to review it for potential redactions. The city countered that it had provided the requested documents within a reasonable timeframe and that the delay was justified to ensure compliance with public records laws.
The case reached the Ohio Court of Appeals after the Court of Claims initially sided with a special master who found in favor of Di Fiore. The special master recommended that the court deny the city's motion to dismiss, stating that the city had unreasonably delayed providing access to the ticket. However, the city objected to this finding, arguing that the special master had misunderstood the facts of the case.
On October 22, 2025, the Court of Claims reviewed the objections and ultimately agreed with the city. The court found that the special master had erred in concluding that Di Fiore was allowed to inspect the ticket on January 27 and that the city had waived any redaction issues. The court stated, "the Department did not unreasonably delay production of the record" and noted that four business days was a reasonable time for the city to review the records.
The Ohio Court of Appeals, led by Presiding Judge Mary J. Boyle, upheld the lower court's ruling. The court emphasized that the determination of whether a public office has complied with its duty to provide records promptly depends on the specific facts and circumstances of each case. The court stated, "the fact that the City’s review ultimately revealed no information requiring redaction does not retroactively prevent the City from having the opportunity to conduct the review process."
In its ruling, the court also addressed Di Fiore's argument regarding the burden of proof. Di Fiore claimed that because he established the request was not fulfilled promptly, the burden shifted to the city to justify the delay. However, the court clarified that the burden of proof remained with Di Fiore throughout the process, as the city had ultimately complied with his request without any redactions.
The court's decision in this case reinforces the importance of understanding the legal standards surrounding public records requests in Ohio. It highlights that while public offices must provide access to records in a timely manner, they are also allowed reasonable time to review records for potential exemptions or redactions.
This ruling may have broader implications for future public records requests in Ohio, as it sets a precedent for how courts may interpret what constitutes a reasonable delay. It serves as a reminder for requesters that while they have rights to access public records, public offices also have responsibilities to ensure compliance with the law.
Looking ahead, it is unclear whether Di Fiore will seek further legal recourse following this ruling. The court's decision is final unless appealed to a higher court. As of now, there are no related cases pending that could affect this ruling.