State ex rel. Ames v. Regional Income Tax Agency Bd. of Trustees

2025 Ohio 4379
CourtOhio Court of Appeals
DecidedSeptember 17, 2025
Docket115078
StatusPublished

This text of 2025 Ohio 4379 (State ex rel. Ames v. Regional Income Tax Agency Bd. of Trustees) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State ex rel. Ames v. Regional Income Tax Agency Bd. of Trustees, 2025 Ohio 4379 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. Ames v. Regional Income Tax Agency Bd. of Trustees, 2025-Ohio-4379.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO EX REL., : BRIAN M. AMES, : Relator, : No. 115078 v. : REGIONAL INCOME TAX AGENCY BOARD OF TRUSTEES, :

Respondent. :

JOURNAL ENTRY AND OPINION

JUDGMENT: WRIT DENIED DATED: September 17, 2025

Writ of Mandamus Motion Nos. 585253, 585383, and 585929 Order No. 587824

Appearances:

Brian M. Ames, pro se.

Gordon Rees Scully Mansukhani LLP, Gregory Brunton, and Eric Bravo, for respondent.

MICHAEL JOHN RYAN, J.:

Relator Brian M. Ames (“Ames”) has filed a complaint for mandamus

against respondent, the Regional Income Tax Agency Board of Trustees (“RITA”). Ames seeks a writ of mandamus to compel RITA to provide him with all requested

public records and statutory damages. Because Ames failed to properly make his

public-records request by electronic submission, certified mail, or hand delivery, we

find that Ames is not entitled to any of the requested relief. We also find that all

requested public records have been provided to Ames, which renders his request for

mandamus moot. Finally, Ames is not entitled to statutory damages. We grant

RITA’s motion for summary judgment and deny Ames’s motion for summary

judgment.

I. PROCEDURAL HISTORY AND FACTS

Ames, requested by email, four public records: 1) the rules for

notification of public meetings as required by R.C. 121.22(F) in effect for the years

2023, 2024, and 2025; 2) the signed meeting minutes for the years 2023, 2024, and

2025; 3) the notices of special and rescheduled regular meeting minutes for the

years 2023 and 2024; and 4) the current bylaws. Ames sent the email requests to

Rick J. Carbone, former legal counsel for RITA. See exhibit Nos. 1, 2, 3, and 4

attached to Ames’s complaint for mandamus. The four emails were sent to Rick

Carbone’s obsolete and unmonitored email address, specifically

rcarbone@ritaohio.com, on February 17, 2025, March 9, 2025, March 10, 2025, and

March 24, 2025.

On April 19, 2025, Ames sent to RITA, by certified mail, a completed

“Ohio Court of Claims Public Records Access Formal Complaint” with copies of the

four prior public-records requests. The certified mail was received by RITA on April 23, 2025. On April 24, 2025, RITA’s chief legal counsel acknowledged receipt

of Ames’s public-records request and further indicated that a response to the request

would be made within seven to ten business days. On April 29, 2025, Ames filed his

complaint for a writ of mandamus. On April 30, 2025, RITA responded to Ames’s

request for public records and provided responses to each of the public-records

requests. On June 11, 2025, RITA filed an answer to the complaint for a writ of

mandamus and a motion for summary judgment. On June 17, 2025, Ames filed a

cross-motion for summary judgment and an opposition to RITA’s motion for

summary judgment. On July 7, 2025, RITA filed a brief in opposition to Ames’s

cross-motion for summary judgment.

II. LEGAL ANALYSIS

A. Failure to Demonstrate Proper Request for Public Records

A writ of mandamus is the remedy to compel compliance with

R.C. 149.43, Ohio’s Public Records Act. State ex rel. Castellon v. Cuyahoga Cty.

Prosecutor’s Office, 2025-Ohio-2787; State ex rel. Physicians Commt. For

Responsible Medicine v. Ohio State Univ. Bd. of Trustees, 2006-Ohio-903, ¶ 6.

In order to obtain a writ of mandamus pursuant to R.C. 149.43, the party requesting

public records must prove by clear and convincing evidence that the request was

made by certified mail, hand delivery, or electronic submission to the entity or

person responsible for maintaining the public records. State ex rel. Ware v. Akron

Police Dept., 2025-Ohio-1198; State ex rel. McDougald v. Greene, 2020-Ohio-3686. A review of Ames’s complaint for mandamus demonstrates that his

original four public-records requests were sent, via email, to RITA’s former chief

legal counsel, Rick Carbone, at rcarbone@ritaohio.com. The affidavit of Amber E.

Greenleaf Duber, the current chief legal counsel for RITA, attached to RITA’s motion

for summary judgment, clearly establishes that Ames did not email his four requests

for public records to the person responsible for public records at RITA. The affidavit

clearly demonstrates that Rick Carbone, the former chief legal counsel for RITA,

retired in 2013 and that the four emails requesting public records were not delivered

to the proper email portal that triggered a required response on the part of RITA to

provide the requested public records. State ex rel. Mobley v. Grabman, 2025-Ohio-

2257; State ex rel. Gabbard, 2025-Ohio-1022, ¶ 8; State ex rel. Mobley v.

Viehweger, 2024-Ohio-4748, ¶ 11. In fact, the official website for RITA provides the

correct email portal through which Ames should have filed his email request for

public records.1 See Regional Income Tax Agency, Contact Us – Media and Public

Records Request Contact, https://www.ritaohio.com/About/Contact/Media

(accessed Sept. 12, 2025) [https://perma.cc/92DC-9CR8]. Thus, based upon the

We take judicial notice of RITA’s website that contains the portal for 1

requesting public records by email. Evid.R. 201 governs judicial notice of adjudicative facts. A court may take judicial notice of a fact not subject to reasonable dispute that is capable of accurate and ready determination by resort to sources whose accuracy cannot reasonably be questioned. Evid.R. 201(B). States Res. Corp. v. Hendy, 2011-Ohio-1900, ¶ 18; Malone v. Berry, 2007-Ohio- 6501, ¶ 13 (10th Dist.). four original emails sent by Ames to a non-employee of RITA, there existed no duty

to provide the requested records under R.C. 149.43.

B. Request for Public Records is Moot

Notwithstanding the initial failure of Ames to properly request public

records from RITA, Ames’s request for public records eventually complied with

R.C. 149.43. On April 23, 2025, RITA received by certified mail an “Ohio Court of

Claims Public Records Access Formal Complaint” with copies of the four prior

public-records requests. On April 24, 2025, the chief legal officer for RITA

acknowledged Ames’s request for public records, via email, and indicated that the

request would be responded to within seven to ten days.

On April 30, 2025, RITA’s chief legal officer responded to the public-

records request and provided, via email, copies of the requested public records and

stated:

Attached please find the records that are responsive to your request, which include:

1. RITA Board of Trustees Bylaws setting forth rules for notification of meetings in effect for 2023, 2024, and 2025;

2. RITA Board meeting minutes for 2023 2024, and 2025;

3. As the RITA Board of Trustees did not hold any special meetings in 2023 and 2024, nor did it reschedule any meetings, no records are responsive to the notices request; and

4. RITA Board of Trustee Bylaws (already provided to satisfy request number 1). In addition, the affidavit of RITA’s chief legal officer, attached to the motion for

summary judgment of RITA, provides that all requested public-records have been

provided or do not exist. The Supreme Court of Ohio has opined that

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2025 Ohio 4379, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-ames-v-regional-income-tax-agency-bd-of-trustees-ohioctapp-2025.