State ex rel. Multimedia Inc. v. Snowden

Mandamus is the proper remedy to compel compliance with Ohio’s Public Records Act, R.C. 149.43. State ex rel. Steckman v. Jackson (1994), 70 Ohio St.3d 420, 426, 639 N.E.2d 83, 88-89. Snowden concedes that the requested records are “records” for purposes of R.C. 149.43 and that they are held by the city’s Police Division, which is a “public office.” See R.C. 149.011(A) and (G). However, Snowden asserts that the records are excepted from disclosure under R.C. 149.43(A)(2) as “confidential law enforcement investigatory records.”

R.C. 149.43(A)(1) excepts confidential law enforcement…