The Ohio Supreme Court issued a significant ruling on July 7, 2026, regarding public records requests made by inmates. The case, known as State ex rel. Mobley v. Banks (Docket No. 2024-0219), involved Alphonso Mobley Jr., who sought access to several documents from the Ohio Department of Rehabilitation and Correction (ODRC). The court's decision impacts how public records requests are handled, particularly in the context of inmate rights and the obligations of public agencies.
Mobley, an inmate, filed a lawsuit seeking a writ of mandamus after his request for four specific items was partially denied by the ODRC. This ruling is crucial as it clarifies the extent of public access to records, especially those related to inmate medical and mental health information, and the responsibilities of public records custodians.
The dispute began when Mobley submitted a letter to the ODRC in December 2023, requesting copies of emails concerning him, a certificate of disposal, an authorization for crisis precaution, and a mental health protocol. The public records custodian, Jason Ware, responded by stating that Mobley could receive two of the requested items if he paid the copying costs. However, he denied the request for the authorization form, claiming it was a medical record exempt from disclosure. Mobley did not follow up on the copying costs and instead opted to file a lawsuit.
The case reached the Ohio Supreme Court after Mobley argued that the ODRC failed to comply with the Public Records Act. The court had to determine whether the authorization-for-crisis-precaution form was indeed a medical record exempt from public disclosure and whether Mobley was entitled to the other requested documents.
The court ruled that Mobley was entitled to the authorization-for-crisis-precaution form because the ODRC did not adequately demonstrate that it qualified as a medical record under Ohio law. Justice Pat DeWine, writing for the court, stated, "the director has failed to show that the authorization-for-crisis-precaution form is an exempt medical record." This ruling allows Mobley access to that specific document.
However, the court denied Mobley's requests for the emails and the mental health protocol, stating that the custodian had complied with the Public Records Act by offering to provide these items upon payment of copying costs. The court emphasized that the Public Records Act does not require a public office to provide a detailed statement of costs before fulfilling a request.
Additionally, the court ruled against Mobley’s request for statutory damages, citing that the ODRC's assertion of the medical-record exemption was reasonable and aligned with public policy. The court noted that the exemption exists to protect sensitive medical information of inmates, and the ODRC acted within its rights by withholding the authorization form until a proper request was made.
This ruling has significant implications for inmates and public records requests in Ohio. It establishes that while inmates have the right to access certain public records, there are limitations based on the nature of the records requested. The decision also clarifies that public agencies are not obligated to provide cost estimates upfront when responding to records requests, as long as they inform requesters that costs will apply.
Looking ahead, the ruling may influence how public records custodians handle requests from inmates and other individuals. It reinforces the need for cooperation between requesters and custodians while also highlighting the balance between transparency and the protection of sensitive information.
As for potential appeals, the court's decision is final unless a higher court chooses to review it. There are no related cases pending that directly connect to this ruling, but it may set a precedent for future public records disputes involving inmates in Ohio.