State ex rel. Ames v. Revere Local School Dist. Bd. of Edn.

2025 Ohio 4818
CourtOhio Court of Appeals
DecidedOctober 22, 2025
Docket31181
StatusPublished

This text of 2025 Ohio 4818 (State ex rel. Ames v. Revere Local School Dist. Bd. of Edn.) 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. Revere Local School Dist. Bd. of Edn., 2025 Ohio 4818 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. Ames v. Revere Local School Dist. Bd. of Edn., 2025-Ohio-4818.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

STATE OF OHIO EX REL. BRIAN M. AMES

Relator

v. C.A. No. 31181

REVERE LOCAL SCHOOL DISTRICT BOARD OF EDUCATION C/O THE TREASURER ORIGINAL ACTION IN MANDAMUS

Respondent

Dated: October 22, 2025

PER CURIAM.

{¶1} Relator, Brian M. Ames, has petitioned this Court for a writ of mandamus against

Respondent, Revere Local School District Board of Education c/o The Treasurer (“the Board”).

He asks this Court to order the Board to release public records and to award him statutory damages,

attorney fees, and costs. After the Board filed its answer, both parties moved for summary

judgment. For the following reasons, we deny Mr. Ames’ motion for summary judgment and grant

the Board’s motion for summary judgment.

Background

{¶2} Mr. Ames1 emailed the Board via its treasurer to request copies of four items: (1)

the rule for notifications of meetings in effect in 2023 and 2024, (2) the approved meeting minutes

1 Mr. Ames used a pseudonym to communicate with the treasurer. To simplify matters, we will refer to him strictly by his legal name. 2

for 2023 and 2024, (3) the notices for special meetings held in 2023 and 2024, and (4) the current

records retention schedule (RC-2). The treasurer sent a reply and responded to each request. As

to items one, two, and four, the treasurer directed Mr. Ames to specific sections of the School

District’s website. As to item three, the treasurer sent 12 files containing PDFs of special meeting

notifications and agendas.

{¶3} Mr. Ames responded to the treasurer’s email. He informed the treasurer that three

of his responses did not satisfy the records request Mr. Ames had made. As to item two, Mr. Ames

wrote that the meeting minutes posted on the School District’s website were not signed and,

therefore, were not approved or official. As to item three, he wrote that the attached files did not

include any notices of work sessions, which were also special meetings. As to item four, he wrote

that the School District’s website only contained a policy for creating a records retention schedule,

not the actual schedule.

{¶4} The treasurer sent another reply to Mr. Ames. As to item two, the treasurer wrote

that the meeting minutes posted on the School District’s website were Board-approved and were

“in the form in which they are retained for District records . . . .” As to item three, he wrote that

work sessions were regular meetings, not special meetings. As to item four, he directed Mr. Ames

to page six of the policy Mr. Ames had viewed on the School District’s website. The treasurer

indicated that there were “no further records responsive to any of these items.” One day after Mr.

Ames received the treasurer’s reply, he filed this mandamus action.

Summary Judgment Standard

{¶5} To prevail on a motion for summary judgment, the moving party must be able to

point to evidentiary materials that show there is no genuine issue as to any material fact, and that

the moving party is entitled to judgment as a matter of law. Dresher v. Burt, 75 Ohio St.3d 280, 3

292-293 (1996). Once a moving party satisfies its burden of supporting its motion for summary

judgment with sufficient and acceptable evidence pursuant to Civ.R. 56(C), Civ.R. 56(E) provides

that the non-moving party may not rest upon the mere allegations or denials of the moving party’s

pleadings. Rather, the non-moving party has a reciprocal burden of responding by setting forth

specific facts, demonstrating that a “genuine triable issue” exists to be litigated. State ex rel.

Zimmerman v. Tompkins, 75 Ohio St.3d 447, 449 (1996). This Court “‘may consider evidence

other than that listed in Civ.R. 56 when there is no objection.’” State ex rel. Jefferson v. Russo,

2020-Ohio-338, ¶ 14, quoting State ex rel. Spencer v. E. Liverpool Planning Comm., 80 Ohio St.3d

297, 301 (1997).

The Public Records Act and Mandamus

{¶6} “The Public Records Act requires a custodian of public records to make records

available when properly requested.” State ex rel. Ames v. Big Walnut Loc. Sch. Dis. Bd. of Edn.,

2025-Ohio-2493, ¶ 9. “Mandamus is the appropriate remedy to compel compliance with R.C.

149.43, Ohio’s Public Records Act.” State ex rel. Physicians Commt. for Responsible Medicine v.

Ohio State Univ. Bd. of Trustees, 2006-Ohio-903, ¶ 6. To obtain a writ of mandamus, “the

requester must prove by clear and convincing evidence a clear legal right to the record and a

corresponding clear legal duty on the part of the respondent to provide it.” State ex rel. Griffin v.

Sehlmeyer, 2021-Ohio-1419, ¶ 10.

{¶7} “‘In general, providing the requested records to the relator in a public-records

mandamus case renders the mandamus claim moot.’” State ex rel. Mobley v. LaRose, 2024-Ohio-

1909, ¶ 7, quoting State ex rel. Toledo Blade Co. v. Toledo-Lucas Cty. Port Auth., 2009-Ohio-

1767, ¶ 14. See also State ex rel. Eubank v. McDonald, 2013-Ohio-72, ¶ 1 (“Mandamus will not

lie to compel an act that has already been performed.”). “Additionally, ‘[a]bsent contrary evidence 4

in the record,’ averments that all responsive records have been provided establish that the

mandamus claim is moot.” State ex rel. Ames v. Concord Twp. Bd. of Trustees, 2025-Ohio-

1027, ¶ 30, quoting State ex rel. Kesterson v. Kent State Univ., 2018-Ohio-5110, ¶ 18.

The Records Requested in this Matter

{¶8} It is undisputed that Mr. Ames made a public records request for four items in this

matter: (1) the rule for notifications of meetings in effect in 2023 and 2024, (2) the approved

meeting minutes for 2023 and 2024, (3) the notices for special meetings held in 2023 and 2024,

and (4) the current records retention schedule (RC-2). In his petition for a writ of mandamus, he

alleges that the Board failed to fully respond to his request. To facilitate our review of the

competing motions for summary judgment on the petition, we will consider each requested item

in turn.

1. The Rule for Notifications of Meetings in Effect in 2023 and 2024

{¶9} R.C. 121.22 sets forth Ohio’s Open Meetings Act. The statute provides, in relevant

part, that

[e]very public body, by rule, shall establish a reasonable method whereby any person may determine the time and place of all regularly scheduled meetings and the time, place, and purpose of all special meetings.

R.C. 121.22(F).

{¶10} Mr. Ames does not dispute that, in response to his request for item one, the Board

supplied him with directions to access Policy 1.11 on the School District’s website. Mr. Ames

filed a copy of the policy as an exhibit to his complaint. In his motion for summary judgment, he

argues that Policy 1.11 “is of no effect” because, with respect to work sessions, the District’s policy

and its practice conflict. According to Mr. Ames, the policy does not treat work sessions as regular

meetings, but the Board’s treasurer insists that work sessions are regular meetings. Mr. Ames 5

argues that the Board failed to provide him documents responsive to his request because, as to

work sessions, Policy 1.11 was clearly not “in effect” as a matter of practice for the years 2023

and 2024.

{¶11} The Board admits that Policy 1.11 is the School District’s meeting notice rule. It

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Related

State ex rel. Eubank v. McDonald
2013 Ohio 72 (Ohio Supreme Court, 2013)
State ex rel. Jefferson v. Russo (Slip Opinion)
2020 Ohio 338 (Ohio Supreme Court, 2020)
State ex rel. Griffin v. Sehlmeyer (Slip Opinion)
2021 Ohio 1419 (Ohio Supreme Court, 2021)
Dresher v. Burt
662 N.E.2d 264 (Ohio Supreme Court, 1996)
State ex rel. Zimmerman v. Tompkins
663 N.E.2d 639 (Ohio Supreme Court, 1996)
State ex rel. Kesterson v. Kent State Univ.
123 N.E.3d 895 (Ohio Supreme Court, 2018)
State ex rel. Grim v. New Holland
2024 Ohio 4822 (Ohio Supreme Court, 2024)
State ex rel. Ames v. Big Walnut School Dist. Bd. of Edn.
2025 Ohio 2493 (Ohio Supreme Court, 2025)
State ex rel. Baker v. Treglia
2025 Ohio 2816 (Ohio Supreme Court, 2025)
State ex rel. Ames v. Concord Twp. Bd. of Trustees
2025 Ohio 1027 (Ohio Supreme Court, 2025)
State ex rel. Mobley v. LaRose
2024 Ohio 1909 (Ohio Supreme Court, 2024)
State ex rel. Spencer v. E. Liverpool Planning Comm.
1997 Ohio 77 (Ohio Supreme Court, 1997)
State ex rel. Long v. Cardington Village Council
2001 Ohio 130 (Ohio Supreme Court, 2001)

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Bluebook (online)
2025 Ohio 4818, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-ames-v-revere-local-school-dist-bd-of-edn-ohioctapp-2025.