The Ohio Supreme Court recently issued a ruling in the case of State ex rel. Mobley v. Franklin County Board of Commissioners, affirming a lower court's dismissal of a public records request dispute. The court's decision, filed on July 10, 2026, clarifies the obligations of public offices under Ohio's Public Records Act, particularly when it comes to duplicative requests. The ruling affects individuals seeking access to public records and sets a precedent regarding how public offices handle such requests.

Alphonso Mobley Jr. had sought records from the Franklin County Board of Commissioners, specifically a paper copy of a statement prepared by the Franklin County Prosecuting Attorney for the year 2020. The board denied his request, claiming it was duplicative of an earlier request that had already been fulfilled by the Franklin County Prosecutor's Office. Mobley then filed a lawsuit in the Tenth District Court of Appeals, seeking a writ of mandamus to compel the board to provide the records and to award him statutory damages.

The Tenth District Court of Appeals granted the board's motion to dismiss, stating that Mobley had already received the requested record and that his claim for statutory damages was unwarranted. The court concluded that the board's initial denial was made in reasonable reliance on existing case law, which indicated that public offices are not obligated to respond to duplicative requests. Mobley subsequently appealed the decision to the Ohio Supreme Court.

The Ruling

The Ohio Supreme Court upheld the Tenth District's ruling, affirming the dismissal of Mobley's claim for a writ of mandamus as moot and denying his request for statutory damages. The court ruled that the board reasonably believed its denial of Mobley's request did not constitute a failure to comply with the Public Records Act, R.C. 149.43. Justice Pat DeWine authored the opinion, which was joined by Justices Fischer, Brunner, Deters, Hawkins, and Shanahan. Chief Justice Maureen O'Connor concurred in part and dissented in part.

The court stated, "the Tenth District did not abuse its discretion in finding that based on existing case law, the board reasonably would have believed its denial of Mobley’s request was not a failure to comply with its obligation under the Public Records Act."

The court's decision emphasized that a public office is not required to respond to a duplicative request already fulfilled by another office. The ruling cited previous cases, including State ex rel. Cushion v. City of Massillon, which supported the view that public offices need not respond to duplicate requests.

Impact

This ruling has significant implications for how public records requests are handled in Ohio. It clarifies that public offices can deny requests they believe to be duplicative without facing penalties, provided their belief is based on reasonable interpretations of existing case law. This decision may affect individuals seeking public records, as they may need to be more strategic in how they submit requests to avoid duplications that could lead to denials.

Moreover, the ruling reinforces the idea that public offices have some discretion in interpreting their obligations under the Public Records Act. This may lead to more cautious approaches by public offices when responding to requests, as they may rely on interpretations of the law that could protect them from claims of non-compliance.

What's Next

While the ruling in Mobley v. Franklin County Board of Commissioners is final, it is possible that similar cases could arise in the future, particularly as public records laws continue to evolve. Legal experts suggest that individuals seeking public records may need to consider the implications of this ruling when making requests. There is currently no indication that the case will be appealed further.