Gundersen v. Univ. Hts. Hous. Dept.

2025 Ohio 5269
CourtOhio Court of Claims
DecidedOctober 30, 2025
Docket2025-00595PQ
StatusPublished

This text of 2025 Ohio 5269 (Gundersen v. Univ. Hts. Hous. Dept.) is published on Counsel Stack Legal Research, covering Ohio Court of Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gundersen v. Univ. Hts. Hous. Dept., 2025 Ohio 5269 (Ohio Super. Ct. 2025).

Opinion

[Cite as Gundersen v. Univ. Hts. Hous. Dept., 2025-Ohio-5269.]

IN THE COURT OF CLAIMS OF OHIO

CANDACE GUNDERSEN Case No. 2025-00595PQ

Requester Special Master Todd Marti

v. REPORT AND RECOMMENDATION

CITY OF UNIVERSITY HEIGHTS HOUSING DEPARTMENT

Respondent

{¶1} This case is before me for a R.C. 2743.75(F) report and recommendation. I recommend that the court (1) find that respondent unreasonably delayed its response to requester’s April 16, 2025, public records request, (2) order respondent to pay requester’s filing fee, costs, and the other costs of this case, and (3) deny all other relief.

I. Background. {¶2} Requester Candace Gundersen has a dispute with the owners of two properties located within the respondent City of University Heights (“the City”). She made a number of public records requests to the City related to that dispute. {¶3} Two requests are central to this case. On April 15, 2025, she requested copies of “any applicable ordinance timelines, policies, or procedures governing the referral process to the prosecutor’s office” of housing code violations. On April 16, 2025, she requested copies of various records related to the two properties that are the subject of the dispute mentioned above. Complaint, filed June 23, 2025, pp. 6, 14.1 {¶4} On May 19, 2025, Ms. Gundersen served the City with a draft R.C. 2743.75 complaint as required by R.C. 149.43(C)(1). On May 30, June 3, and June 5, 2025, she made additional public records requests to the City. Id. at pp. 4-12, 21-32.

1 All references to specific pages of requester’s filings are to the pages of the PDF copies

posted on the court’s docket. Case No. 2025-00595PQ -2- REPORT AND RECOMMENDATION

{¶5} Ms. Gundersen filed this case on June 23, 2025. Her complaint sought production of records and findings that the City violated R.C. 149.43(B) by unreasonably delaying its response to her requests and in other ways. Mediation did not resolve the case, so a schedule was set for the parties to file evidence and memoranda supporting their positions. The parties have made the filings allowed by that schedule, making this case ripe for decision. Id., Order Terminating Mediation, entered August 20, 2025; Order, entered September 8, 2025; Order, entered September 10, 2025; Order, entered October 1, 2025; Orders, entered October 14, 2025.

II. Analysis. A. Requester is not entitled to any relief regarding her April 15, 2025, request.

{¶6} Ms. Gundersen makes four claims regarding the City’s response to the April 15 request. None have merit. {¶7} Production. The city has produced no records in response to this request because it asserts that it has no responsive records. Complaint, p. 10. It did not support that assertion with sworn evidence, so Ms. Gundersen was required to provide some evidence that the City has responsive records. Sell v. Trumbull Cty. Juv. Div., 2024-Ohio- 6139, ¶ 6 (Ct. of Cl.). She has not done so. To the contrary, her submissions acknowledge that the city has consistently stated that it does not have these records. Complaint, p. 29; Requester’s Evidence and Exhibits, filed September 5, 2025, p. 9. Her production claim based on this request therefore fails for want of proof. {¶8} Sworn Certification. Ms. Gundersen claims that the City violated R.C. 149.43 by not providing a sworn certification that it has no records responsive to this request. R.C. 149.43 does not require such certifications. Ryan v. City of Ashtabula, 2023-Ohio- 621, ¶ 22. Adopted, 2023-Ohio-1487 (Ct. of Cl.). This claim fails as a matter of law. {¶9} Acknowledgement. Ms. Gundersen claims that the City violated R.C. 149.43 by failing to acknowledge this request. The City provided unrebutted proof that it acknowledged this request on April 18, 2025. Complaint, p. 10. This claim fails for want of proof. Case No. 2025-00595PQ -3- REPORT AND RECOMMENDATION

{¶10} Delay. Ms. Gundersen made this request late on April 15. The City informed her that it had no responsive records on April 18, less than three full days later. Id., pp. 6, 10. That is a reasonably prompt response. {¶11} I therefore recommend that the court grant no relief in connection with requester’s April 15, 2025, public records request.

B. Respondent unreasonably delayed its response to the April 16, 2025, request, but otherwise did not violate R.C. 149.43(B) regarding that request. {¶12} Production. The City asserts, without supporting sworn evidence, that it has produced all records responsive to this request. Ms. Gundersen was consequently required to come forward with some evidence that the City has additional responsive records. Sell, 2024-Ohio-6139, ¶ 6. She has not done so. Her production claim therefore fails for want of proof. {¶13} Acknowledgement. Ms. Gundersen’s claim that the City failed to acknowledge this request is rebutted by the City’s documentary evidence. Complaint, p. 10. {¶14} Delay. R.C. 149.43(B)(1) mandates that “upon request *** a public office *** shall make copies of the requested public record available to the requester *** within a reasonable period of time.” (Emphasis added). A public office’s compliance with that requirement is evaluated based on the facts and circumstances of the request. State ex rel. Morgan v. Strickland, 2009-Ohio-1901, ¶ 10; State ex rel. Kesterson v. Kent State Univ., 2018-Ohio-5108, ¶ 16. Several aspects of this case establish that the City’s delay in responding to the April 16 request violated R.C. 149.43(B)(1). {¶15} First, the delay here is longer than delays found unreasonable in similar cases. Although each delay claim turns on its own facts, some guidance is provided by similar cases. It took the City more than three months to completely respond to Ms. Gundersen’s April 16 request. That is longer than the delays found to be unreasonable in other cases. State ex rel. Ware v. Bur. of Sentence Computation, 2022-Ohio-3562, ¶ 17 (10th Dist.); Jones v. Columbus Div. of Police, 2025-Ohio-465, ¶ 21 (10th Dist.) (Surveying cases). While not conclusive, these cases suggest that the delay involved here was unreasonable. Case No. 2025-00595PQ -4- REPORT AND RECOMMENDATION

{¶16} Second, the request involved a limited number of records and presented limited review/redaction issues. Public offices are given more time to respond to requests for large volumes or diverse types of records. Conversely, they are allowed less time for narrower requests. Compare State ex rel. Shaughnessy v. City of Cleveland, 2016-Ohio- 8447, ¶ 14; Kesterson, 2018-Ohio-5108, ¶ 17; State ex rel. Patituce & Assocs., LLC v. City of Cleveland, 2017-Ohio-300, ¶ 7 (8th Dist.); and Easton Telecom Servs., L.L.C. v. Village of Woodmere, 2019-Ohio-3282, ¶¶ 46-49 (8th Dist.); with Miller v. Ohio Dept. of Education,, 2016-Ohio-8534, ¶ 8 (10th Dist.); State ex rel. Ware v. Bur. of Sentence Computation, 2022-Ohio-3562, ¶ 19 (10th Dist.); and Foulk v. City of Upper Arlington, 2017-Ohio-4249, ¶ 11, adopted 2017-Ohio-5767 (Ct. of Cl.). Relatedly, more time is allowed if the volume or nature of responsive records will make legal review and redaction more time consuming. Compare State ex rel. Cincinnati Enquirer v. Pike Cty. Coroner’s Office, 2017-Ohio-8988, ¶ 59 and Anderson v. Greater Cleveland Regional Transit Auth., 2018-Ohio-3653, ¶ 7, adopted, 2018-Ohio-4596 (Ct. of Cl.) with Miller, 2016-Ohio-8534, ¶ 8; State ex rel. Simonsen v. Ohio Dept. of Rehab. & Correction, 2009-Ohio-442, ¶ 10 (10th Dist.); State ex rel. Korecky v. City of Cleveland, 2020-Ohio-273, ¶ 19 (8th Dist.); Ware, 2022-Ohio-3562, ¶ 19. {¶17} The request at issue here was limited. Quantitively, it generated a relatively small volume of responsive records, approximately 340 pages. Respondent’s Responses to Requester and Responsive Records Provided to Requester, filed September 19, 2025, pp. 7-21, 38-102, 106-325.2 Qualitatively, there were no redactions.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State ex rel. Morgan v. Strickland
2009 Ohio 1901 (Ohio Supreme Court, 2009)
Simonsen v. Dept. of Rehab. Corr., 08ap-21 (2-3-2009)
2009 Ohio 442 (Ohio Court of Appeals, 2009)
State ex rel. Miller v. Ohio Dept. of Edn.
2016 Ohio 8534 (Ohio Court of Appeals, 2016)
Foulk v. Upper Arlington
2017 Ohio 4249 (Ohio Court of Claims, 2017)
Foulk v. Upper Arlington
2017 Ohio 5767 (Ohio Court of Claims, 2017)
Anderson v. Greater Cleveland Regional Transit Auth.
2018 Ohio 3653 (Ohio Court of Claims, 2018)
Anderson v. Greater Cleveland Regional Transit Auth.
2018 Ohio 4596 (Ohio Court of Claims, 2018)
State ex rel. Korecky v. Cleveland
2020 Ohio 273 (Ohio Court of Appeals, 2020)
State ex rel. Schumann v. Cleveland
2020 Ohio 4920 (Ohio Court of Appeals, 2020)
State ex rel. Kesterson v. Kent State Univ.
123 N.E.3d 887 (Ohio Supreme Court, 2018)
State ex rel. Ware v. Sentence Computation Bur.
2022 Ohio 3562 (Ohio Court of Appeals, 2022)
Ryan v. Ashtabula
2023 Ohio 1487 (Ohio Court of Claims, 2023)
Schaffer v. Ohio State Univ.
2024 Ohio 2185 (Ohio Court of Claims, 2024)
State ex rel. Clark-Shawnee Local School Bd. of Edn v. Springfield
2024 Ohio 2483 (Ohio Court of Appeals, 2024)
Sell v. Trumbull Cty. Juvenile Div.
2024 Ohio 6139 (Ohio Court of Claims, 2024)
Jones v. Columbus Div. of Police
2025 Ohio 465 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 5269, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gundersen-v-univ-hts-hous-dept-ohioctcl-2025.