State ex rel. Slager v. Trelka

2024 Ohio 5125, 250 N.E.3d 18, 177 Ohio St. 3d 17
CourtOhio Supreme Court
DecidedOctober 29, 2024
Docket2023-1573
StatusPublished
Cited by2 cases

This text of 2024 Ohio 5125 (State ex rel. Slager v. Trelka) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State ex rel. Slager v. Trelka, 2024 Ohio 5125, 250 N.E.3d 18, 177 Ohio St. 3d 17 (Ohio 2024).

Opinion

[This opinion has been published in Ohio Official Reports at 177 Ohio St.3d 17.]

THE STATE EX REL . SLAGER v. TRELKA ET AL. [Cite as State ex rel. Slager v. Trelka, 2024-Ohio-5125.] Mandamus—Public-records requests—Prison’s public-information officer had no duty to produce records requested by inmate that no longer exist or never existed, create new records to meet inmate’s demands, produce security records exempt from release, produce records in response to inmate’s overly broad request, or produce records available only in medium that would be contraband in violation of prison rules—Writ and relator’s requests for statutory damages and court costs denied. (No. 2023-1573—Submitted September 3, 2024—Decided October 29, 2024.) IN MANDAMUS. __________________ The per curiam opinion below was joined by FISCHER, DEWINE, DONNELLY, STEWART, and DETERS, JJ. KENNEDY, C.J., concurred in part and dissented in part, with an opinion joined by BRUNNER, J.

Per Curiam. {¶ 1} Relator, Michael W. Slager, requests a writ of mandamus compelling the production of public records responsive to numerous requests he made by electronic prison kite. Respondents are Cynthia Davis, the warden of the Southern Ohio Correction Facility (“SOCF”); Brandi Trelka, the warden’s administrative assistant and SOCF’s public-information officer; and a “Ms. Peirce” in the legal department of the Ohio Department of Rehabilitation and Correction (“DRC”). Slager also seeks awards of statutory damages and court costs. We deny Slager’s request for a writ of mandamus and deny his requests for statutory damages and court costs. In addition, we deny respondents’ motion to strike Slager’s merit brief, SUPREME COURT OF OHIO

grant respondents’ motion for leave to amend their merit brief, deny Slager’s motion for leave to file evidence, and grant Slager’s motion for leave to file a revised reply brief. I. BACKGROUND {¶ 2} Between July and October 2023, while an inmate at SOCF, Slager requested numerous public records through the prison’s electronic-kite system. Trelka, whose duties include responding to inmates’ public-records requests, replied to Slager’s kites. Slager’s records requests and Trelka’s responses to them are detailed below. {¶ 3} Slager commenced this action in December 2023, alleging that respondents had failed to provide him with copies of the records he had requested. Respondents filed a motion to dismiss Slager’s complaint. On March 13, 2024, we denied the motion in part and ordered respondents to file an answer as to 15 of the records requests attached to the complaint.1 2024-Ohio-880. We issued an alternative writ as to those 15 requests, granted respondents’ motion to dismiss as to the remaining requests, and set a schedule for the presentation of evidence and merit briefing. Id. Trelka has submitted her affidavit and copies of the relevant correspondence between Slager and herself. {¶ 4} Before addressing the merits of Slager’s complaint, we first consider the parties’ pending motions, each of which is unopposed. II. PENDING MOTIONS A. Respondents’ Motion to Strike Slager’s Merit Brief {¶ 5} Respondents move to strike Slager’s merit brief on multiple grounds. First, they argue that Slager’s brief does not comply with S.Ct.Prac.R. 16.02(C), which provides that a merit brief shall not exceed 50 numbered pages “exclusive of the table of contents, the table of authorities cited, the certificate of service, and the

1. Although Davis and “Ms. Peirce” remain respondents in this action, Slager’s allegations against them did not survive the motion to dismiss.

2 January Term, 2024

appendix.” Respondents contend that Slager’s brief is 187 pages long, but that is not exclusive of the items listed in the rule. The body of Slager’s brief is only 32 numbered pages. {¶ 6} Respondents next argue that Slager’s brief does not comply with S.Ct.Prac.R. 16.02(B)(4), which provides that a merit brief shall contain arguments headed by propositions of law. They contend that Slager’s propositions of law are “nonsensical and do not frame a proper legal question” because he “rewrote his public records request and/or replead[ed] the allegations contained in his mandamus Complaint.” While Slager’s brief is repetitive and contains few arguments, it is not devoid of them. Moreover, his arguments are headed by four propositions of law. {¶ 7} Respondents further contend that Slager’s merit brief should be stricken as a sanction for “frivolous conduct” because it does not present any reasonable questions for review, does not comply with this court’s alternative writ limiting the controversy to certain records requests, and admits that Slager has received all requested public records subject to disclosure. They also complain that Slager signed his merit brief with a typewritten “X” rather than his signature, and they argue that the brief therefore does not comply with S.Ct.Prac.R. 3.08 or Civ.R. 11. {¶ 8} S.Ct.Prac.R. 3.08 and Civ.R. 11 both require an unrepresented party to sign any document filed in court. The purpose of the signature is to certify that the party has read the document being filed, that to the best of the party’s “knowledge, information, and belief there is good ground to support it,” and that “it is not interposed for delay.” Civ.R. 11. “If a document is not signed or is signed with intent to defeat the purpose of this rule, it may be stricken as sham and false and the action may proceed as though the document had not been served.” Id. Here, Slager’s failure to affix his signature to his merit brief appears to be merely an oversight. All other documents that Slager filed in this court include his signature.

3 SUPREME COURT OF OHIO

Respondents’ position—that Slager willfully violated the rule “in an attempt to disavow responsibility for filing his noncompliant brief and as a way to avoid any possible sanctions”—is unfounded. {¶ 9} Finally, none of the alleged deficiencies in Slager’s merit brief have prevented respondents from responding to Slager’s arguments, nor do they hinder our ability to issue a decision addressing them. See, e.g., State ex rel. Sultaana v. Mansfield Corr. Inst., 2023-Ohio-1177, ¶ 13, citing State ex rel. Physicians Commt. for Responsible Medicine v. Ohio State Univ. Bd. of Trustees, 2006-Ohio-903, ¶ 14. For these reasons, we deny respondents’ motion to strike Slager’s merit brief. B. Respondents’ Motion for Leave to Amend Their Merit Brief {¶ 10} Respondents have also filed a motion for leave to amend their own merit brief to include an inadvertently omitted table of contents and table of authorities. Because Slager does not oppose the motion and no prejudice will result from the amendments, we grant respondents’ motion for leave to amend their merit brief by adding the table of contents and table of authorities that are attached to the motion. C. Slager’s Motion for Leave to File Evidence {¶ 11} The alternative writ we issued on March 13, 2024, ordered that the parties’ evidence be filed by April 11. See 2024-Ohio-880. Slager did not file evidence by that date. On May 28, Slager filed a “motion for leave to file evidence and/or motion for order or [sic] relief pursuant to S.Ct.Prac.R. 4.01(A)(1).” Slager submitted with his motion the proposed evidence that he wants us to consider, in the form of his affidavit and exhibits. Many of these documents are copies of the 15 records-request exhibits that survived respondents’ motion to dismiss. Respondents also submitted copies of these records requests in their evidence. {¶ 12} In his motion, Slager claims that he sent his evidence and merit brief simultaneously to the clerk of the court and that the clerk’s office returned his evidence because it did not comply with our order. The docket reflects that Slager’s

4 January Term, 2024

merit brief was filed on April 18, which was seven days past the deadline for the parties’ evidence.

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 5125, 250 N.E.3d 18, 177 Ohio St. 3d 17, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-slager-v-trelka-ohio-2024.