State ex rel. McCarley v. Ohio Dept. of Rehab. & Corr.

2025 Ohio 1559
CourtOhio Court of Appeals
DecidedMay 1, 2025
Docket20AP-337
StatusPublished

This text of 2025 Ohio 1559 (State ex rel. McCarley v. Ohio Dept. of Rehab. & Corr.) 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. McCarley v. Ohio Dept. of Rehab. & Corr., 2025 Ohio 1559 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. McCarley v. Ohio Dept. of Rehab. & Corr., 2025-Ohio-1559.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Willard McCarley, :

Relator, :

v. : No. 20AP-337

[Ohio] Department of Rehabilitation : (REGULAR CALENDAR) and Correction, : Respondent. :

DECISION

Rendered on May 1, 2025

On brief: Willard McCarley, pro se.

On brief: Dave Yost, Attorney General, and D. Chadd McKitrick, for respondent.

IN MANDAMUS ON OBJECTION TO THE MAGISTRATE’S DECISION DORRIAN, J. {¶ 1} Relator, Willard McCarley, has requested that this court issue a writ of mandamus ordering respondent, Ohio Department of Rehabilitation and Correction (“DRC”), to respond to relator’s public records request. {¶ 2} Pursuant to Civ.R. 53(D) and Loc.R. 13(M) of the Tenth District Court of Appeals, the matter was referred to a magistrate. This court previously adopted a magistrate’s decision and issued a writ of mandamus “ordering [DRC] to produce unredacted copies of institutional records, emails, communications, and other documents as defined in relator’s public records request where the reactions or retentions were based on R.C. 5120.21(F) as ‘records of inmates’ related to relator.” State ex rel. McCarley v. Dept. No. 20AP-337 2

of Rehab. & Corr., 2022-Ohio-3397, ¶ 13 (10th Dist.). Our decision further provided that “[DRC] may continue to withhold or redact records that are not public records under other exceptions to the Public Records Act or constitute ‘records of inmates’ under R.C. 5120.21(F) related to individuals other than relator.” Id. {¶ 3} As explained in the magistrate’s decision appended hereto, the dispute over production of the records sought by relator continued after our decision, resulting in additional proceedings before the magistrate. The complete history of the additional proceedings is set forth in the magistrate’s decision, but the gravamen of the dispute is relator’s assertion that DRC has failed to comply with this court’s prior decision. Ultimately, the magistrate ordered DRC to provide redacted and unredacted copies of the materials it had provided to relator following this court’s prior decision for in camera review, along with a privilege log identifying the basis for the redactions and a memorandum of law supporting the redactions. Relator moved for those documents to be placed under seal and objected to certain documents that were provided for in camera review. After a review of the parties’ filings and the documents submitted for in camera review, the magistrate issued the attached decision, finding that DRC improperly redacted certain documents and recommending that this court grant relator’s motion to show cause, find DRC in contempt, and impose a $1,000 sanction to be stayed so that DRC can purge the contempt by providing responsive records without the improper redactions within 30 days. The magistrate also recommended that this court overrule relator’s objection to DRC’s response and deny relator’s motion to place the documents produced for in camera review under seal. {¶ 4} DRC has filed the following objection to the magistrate’s decision: Respondent objects to the Magistrate’s recommendation to order the removal of the redaction of a third column that appears on the following pages: 262-265, 270-287, 304-316, and 318-319, which contains a Risk Assessment score for the inmates listed on that page. R.C. 5120.115(B).

{¶ 5} DRC submitted for in camera review redacted and unredacted copies of the 319 pages of documents that it provided to relator in response to our prior decision, along with a privilege log identifying the basis for DRC’s redactions. As explained in the magistrate’s decision, DRC’s privilege log and memorandum of law asserted its redactions No. 20AP-337 3

were justified by R.C. 149.43, 149.433, 5120.21(F), and Adm.Code 5120-9-49. With limited exception, the magistrate found that DRC failed to provide sufficient evidence to support the redactions. {¶ 6} DRC only objects to the magistrate’s decision to the extent it directs DRC to provide unredacted copies of pages 262-319 of the documents submitted to the magistrate for in camera review. Citing the statute for the first time in its objection, DRC asserts that a portion of the information contained on pages 262-319 is exempt from the Public Records Act under R.C. 5120.115(B). {¶ 7} Under R.C. 5120.114(A), DRC is required to select a “single validated risk assessment tool for adult offenders” for use by courts, probation departments, correctional facilities, halfway houses, the adult parole authority, and the parole board. R.C. 5120.115(B) expressly provides that “[a]ll reports generated by or data collected in the risk assessment tool are confidential information and are not a public record.” For purposes of R.C. 5120.115, “public record” is defined to have the same meaning as in R.C. 149.43. R.C. 5120.115(C). {¶ 8} Pages 262-319 of the documents submitted by DRC appear to consist of a table or spreadsheet composed of six columns, respectively labeled as Inmate #, Name, Risk, Release, Recommended, and R/W.1 The table contains information corresponding to those fields for various inmates. DRC originally redacted all the information on pages 262- 319, including the labels of the columns. DRC now objects to the magistrate’s order to the extent it would require DRC to release the information contained in the third column, labeled “Risk,” asserting that column contains the risk assessment score for each inmate identified in the table. In support of this claim, DRC provided an affidavit from an administrative employee attesting that the “Risk” column contains data from reports generated from a single validated risk tool. {¶ 9} DRC admits it mistakenly cited the wrong authority in the privilege log to support redaction of the risk assessment scores. DRC argues that notwithstanding that error, this court should reject the magistrate’s conclusion that it failed to establish an

1 It appears that due to formatting or printing issues, in some instances the fifth column (“Recommended”)

and/or the sixth column (“R/W”) falls on a separate page than the columns that preceded it. No. 20AP-337 4

exception from the Public Records Act with respect to the “Risk” column of the table contained on pages 262-319. {¶ 10} “Exceptions to disclosure under the Public Records Act are strictly construed against the public-records custodian, and the custodian has the burden to establish the applicability of an exception.” State ex rel. Miller v. Ohio State Hwy. Patrol, 2013-Ohio- 3720, ¶ 23. The Supreme Court of Ohio has held that “a public-records custodian may meet his burden when the stated exemption upon which he relies is ‘based on risks that are . . . apparent within the records themselves.’ ” McDougald v. Greene, 2020-Ohio-4268, ¶ 10, quoting State ex rel. Rogers v. Dept. of Rehab. & Corr., 2018-Ohio-5111, ¶ 15. The court further declared that “when the applicability of [an] exemption is obvious from the face of the documents, this court will not sacrifice [the public interests protected by that exemption] simply because a party should have done a better job setting forth the obvious.” Id. at ¶ 13. {¶ 11} In this case, despite DRC’s failure to cite the applicable statute in its privilege log, the affidavit submitted in support of DRC’s objection, and the face of the documents establish that the information contained in the “Risk” column of the table contained on pages 262-319 is exempt from disclosure under the Public Records Act pursuant to R.C. 5120.115(B). Accordingly, we sustain DRC’s objection and modify the magistrate’s decision with respect to whether DRC established justification for redaction of information on pages 262-319. DRC may redact the information contained in the “Risk” column of the table set forth on pages 262-319.

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Bluebook (online)
2025 Ohio 1559, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-mccarley-v-ohio-dept-of-rehab-corr-ohioctapp-2025.