State ex rel. Frasure v. Wyoming Police Dept.

2025 Ohio 1751
CourtOhio Court of Appeals
DecidedMay 16, 2025
DocketC-240537
StatusPublished

This text of 2025 Ohio 1751 (State ex rel. Frasure v. Wyoming Police Dept.) 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. Frasure v. Wyoming Police Dept., 2025 Ohio 1751 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. Frasure v. Wyoming Police Dept., 2025-Ohio-1751.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, EX REL. JOSEPH : APPEAL NO. C-240537 FRASURE, TRIAL NO. A-2300979 : Relator-Appellant, : vs. JUDGMENT ENTRY : CITY OF WYOMING POLICE DEPARTMENT, :

CITY OF WYOMING, :

and :

HAMILTON COUNTY SHERIFF’S : DEPARTMENT, : Respondents-Appellees. :

This cause was heard upon the appeal, the record, and the briefs. The judgment of the trial court is affirmed as modified in part, reversed in part, and the cause is remanded for the reasons set forth in the Opinion filed this date. Further, the court holds that there were reasonable grounds for this appeal, allows no penalty, and orders that costs are taxed 50 percent to relator-appellant and 50 percent to respondents-appellees. The court further orders that 1) a copy of this Judgment with a copy of the Opinion attached constitutes the mandate, and 2) the mandate be sent to the trial court for execution under App.R. 27.

To the clerk: Enter upon the journal of the court on 5/16/2025 per order of the court. By:_______________________ Administrative Judge [Cite as State ex rel. Frasure v. Wyoming Police Dept., 2025-Ohio-1751.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, EX REL. JOSEPH : APPEAL NO. C-240537 FRASURE, TRIAL NO. A-2300979 : Relator-Appellant, : vs. OPINION : CITY OF WYOMING POLICE DEPARTMENT, :

HAMILTON COUNTY SHERIFF’S : DEPARTMENT, : Respondents-Appellees. :

Civil Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Affirmed as Modified in Part, Reversed in Part, and Cause Remanded

Date of Judgment Entry on Appeal: May 16, 2025

Glenda A. Smith, for Relator-Appellant Joseph Frasure,

Strauss Troy Co., LPA, and Emily Supinger, for Respondents-Appellees Wyoming Police Department and the City of Wyoming,

Connie M. Pillich, Hamilton County Prosecuting Attorney, James Sayre and Michael J. Friedmann, Assistant Prosecuting Attorneys, for Respondent-Appellee the Hamilton County Sheriff’s Department. OHIO FIRST DISTRICT COURT OF APPEALS

CROUSE, Judge.

{¶1} This appeal involves Ohio’s Public Records Act. We are asked to

determine whether the trial court erred in dismissing relator-appellant Joseph

Frasure’s amended petition for a writ of mandamus that sought to compel

respondents-appellees the Wyoming Police Department, the City of Wyoming, and the

Hamilton County Sheriff’s Department (“HCSD”) to produce various records that he

had requested and, relatedly, requested statutory damages, attorney fees, and costs.

{¶2} We hold that the trial court properly determined that Frasure’s

mandamus claim was moot, but that, in light of such determination, the trial court

should have denied Frasure’s petition for a writ of mandamus, rather than dismissing

it. We further hold that the trial court erred in dismissing Frasure’s requests for

statutory damages, attorney fees, and court costs, because the court relied upon

material outside of the petition to do so.

I. Factual and Procedural History

{¶3} On January 30, 2023, an officer-involved shooting in Wyoming resulted

in the death of Frasure’s son. Frasure filed a petition for a writ of mandamus in the

Hamilton County Court of Common Pleas on March 9, 2023, against the Wyoming

Police Department and the HCSD. The petition named both Frasure and his attorney

as relators, and it stated that they sought to compel the disclosure of the officers’

statements and reports regarding the shooting. It alleged that the relators had

submitted a public-records request to the Wyoming Police Department on February 1,

2023, and were told to contact the HCSD; that the relators received body-camera

footage, a police recording of a call of suspicious activity, and “incident reports

involving 320 Durrell” on February 3, 2023, but did not receive incident reports

involving the shooting; and that, on February 8, 2023, the relators sent another OHIO FIRST DISTRICT COURT OF APPEALS

request for “missing reports” and were again told by the Wyoming Police Department

to contact the HCSD.

{¶4} Service of the summons and petition were sent by certified mail to both

respondents.

{¶5} On March 30, 2023, the Wyoming Police Department filed a motion to

dismiss the petition. The motion argued that (1) the petition was procedurally deficient

because it was not brought by a proper party, i.e., was not brought in the name of the

state on the relation of Frasure, (2) the petition was not brought against a proper party

because the Wyoming Police Department is not sui juris, and (3) the petition failed to

state a claim upon which relief could be granted because it did not allege the necessary

requisites to sustain an action in mandamus. On this last point, the motion contended

that the factual allegations in the petition established that Wyoming had advised the

relators that the requested documents were in the possession of the HCSD and did not

withhold any records.

{¶6} On April 14, 2023, before the trial court could rule on the motion to

dismiss, Frasure filed a motion for leave to file an amended petition for a writ of

mandamus for the purpose of adding “State ex rel. Frasure” to the caption, removing

Frasure’s attorney as a relator, adding the City of Wyoming as a respondent, and

adding allegations concerning “Realtor’s [sic] attempts to get records from the

Sheriff’s Department and April 7th and 11th public records requests.” That same date,

Frasure filed an amended petition for a writ of mandamus that incorporated the

aforementioned changes and information.

{¶7} The amended petition named as respondents the City of Wyoming, the

Wyoming Police Department, and the HCSD. In addition to the allegations that were

contained in the original petition, the amended petition alleged that Frasure

4 OHIO FIRST DISTRICT COURT OF APPEALS

submitted a public-records request to the HCSD via the department’s website on

February 1, 2023; that Frasure faxed a public-records request to the HCSD on

February 8, 2023; that on February 7 and 11, 2023, Frasure sent additional public-

records requests to the City of Wyoming and the HCSD;1 and that the respondents had

not provided him with the requested records. The amended petition sought to compel

the disclosure of the requested records and asked for statutory damages pursuant to

R.C. 149.43(B)(1), attorney fees, and costs.

{¶8} Various exhibits were attached to the amended petition. These included

(1) the City of Wyoming’s email response to Frasure’s February 1, 2023 public-records

request, stating that it would release the body-camera footage on February 3, 2023,

and directing Frasure to submit his request to the HCSD, which was the entity

handling the investigation, (2) the February 8, 2023 public-records request submitted

to the Wyoming Police Department, (3) the City of Wyoming’s response via email to

the February 8, 2023 public-records request, stating that a flash drive with the body-

camera footage was available for pick up at the Wyoming Police Station and that

Wyoming did not have any of the remaining documents that were requested, and

directing Frasure to submit his request to the HCSD, (4) a February 1, 2023 public-

records request submitted to the HCSD, along with the HCSD’s response directing

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Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1751, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-frasure-v-wyoming-police-dept-ohioctapp-2025.