Ohio Supreme Court Awards Prisoner $1,000 for Denied Records Request
by Chuck Sharman
Former Ohio prisoner Ronald Ayers was awarded $1,000 by the state Supreme Court on June 18, 2025, when it found that an official with the state Department of Rehabilitation and Correction (DRC) wrongly denied his public records request, granting a writ of mandamus ordering her to produce it. It was not the first instance in which a ham-handed response to such a request has won an Ohio prisoner thousands of dollars in damages, as PLN has reported. [See, e.g.: PLN, Sep. 2024, p.60.]
In January 2024, Ayers sought a copy of DRC’s records retention schedule, using an electronic “kite” sent to Laura Sackett, the records custodian at the Lake Erie Correctional Institution, which is owned and operated for the DRC under contract by prison profiteer CoreCivic, Inc. Sackett responded 47 days later that the retention schedule was “not specific” to the DRC. But as the Court later recalled, she offered no other justification for her decision to deny the request.
Sackett also asked for clarification of the request. Ayers replied on March 1 that he sought video surveillance camera footage from an August 2023 cell shakedown. Ayers demurred, saying that “legal services” would need to review the request. Eventually, a CoreCivic employee denied it, claiming that the video was not a public record subject to disclosure.
Ayers then filed his mandamus action with the Court, seeking $2,000 in damages for the pair of denied requests. The Court denied Sackett’s motion to dismiss and Ayers’ motion for referral to mediation, ordering the parties to schedule briefs. Ayers responded with a pair of discovery requests, but the Court found both had been mooted.
Sackett argued that Ayers’ suit should be dismissed because he had failed to exhaust the prison’s administrative remedies, as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e. But the Court said that the PLRA did not apply to a mandamus action under the state public records act, R.C. 149.3, and it denied the motion to dismiss.
Sackett also claimed that she was unable to produce the video because prison policy mandated video retention only for a “qualifying event”—such as might have occurred if guards found contraband during the shakedown. Since nothing like that happened, the tapes had been destroyed. “Mandamus will not issue when the uncontroverted evidence shows that the requested documents do not exist,” the Court said, citing State ex rel. Culgan v. Jefferson Cnty. Prosecutor, 176 Ohio St. 3d 543 (2024). Since Ayers failed to meet his burden to prove that the evidence should have been retained, the Court said Sackett need not provide what she didn’t have.
The retention schedule, however, was a document within her possession, and she provided no legal justification for withholding it. Therefore, she was compelled to produce it, and Ayers was awarded statutory damages of $1,000 for her failure to timely do so. See: State ex rel. Ayers v. Sackett, 2025-Ohio-2115.
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