State ex rel. Teagarden v. Dept. of Rehab. & Corr.

2026 Ohio 567
CourtOhio Supreme Court
DecidedFebruary 24, 2026
Docket2025-0479
StatusPublished

This text of 2026 Ohio 567 (State ex rel. Teagarden v. Dept. of Rehab. & Corr.) 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. Teagarden v. Dept. of Rehab. & Corr., 2026 Ohio 567 (Ohio 2026).

Opinion

[Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as State ex rel. Teagarden v. Dept. of Rehab. & Corr., Slip Opinion No. 2026-Ohio-567.]

NOTICE This slip opinion is subject to formal revision before it is published in an advance sheet of the Ohio Official Reports. Readers are requested to promptly notify the Reporter of Decisions, Supreme Court of Ohio, 65 South Front Street, Columbus, Ohio 43215, of any typographical or other formal errors in the opinion, in order that corrections may be made before the opinion is published.

SLIP OPINION NO. 2026-OHIO-567 THE STATE EX REL. TEAGARDEN v. OHIO DEPARTMENT OF REHABILITATION AND CORRECTION.

[Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as State ex rel. Teagarden v. Dept. of Rehab. & Corr., Slip Opinion No. 2026-Ohio-567.] Mandamus—Public-records requests—Inmate not entitled to writ for public records that he has already been provided, records that he has failed to show exist and are maintained by the public office, records that he made a duplicate request for, or records that he has failed to pay the copying cost for—Inmate entitled to writ for public records he requested that public office failed to provide and that public office does not deny it maintains—Writ granted in part and denied in part—Court costs and statutory damages awarded. (No. 2025-0479—Submitted November 18, 2025—Decided February 24, 2026.) IN MANDAMUS. __________________ SUPREME COURT OF OHIO

The per curiam opinion below was joined by KENNEDY, C.J., and DEWINE, BRUNNER, DETERS, HAWKINS, and SHANAHAN, JJ. FISCHER, J., concurred but would not award statutory damages.

Per Curiam. {¶ 1} Relator, Trevor Teagarden, filed this public-records mandamus action against respondent, the Ohio Department of Rehabilitation and Correction (“ODRC”), claiming that he submitted multiple public-records requests for 11 items and that ODRC still has not provided him with those items. Teagarden seeks a writ of mandamus ordering ODRC to provide him with the 11 requested items. He also seeks awards of statutory damages and court costs. {¶ 2} For the following reasons, we grant the writ in part, ordering ODRC to provide Teagarden with item Nos. 3 and 5 through 8 once he pays any applicable copying costs for those records. But we deny the writ with respect to item Nos. 1, 2, 4, and 9 through 11. Because we grant the writ for five of the requests, we award Teagarden court costs; we also award him $5,000 in statutory damages. I. FACTS AND PROCEDURAL HISTORY A. Facts {¶ 3} Teagarden is incarcerated at the Southeastern Correctional Institution. He was previously incarcerated at the Pickaway Correctional Institution (“PCI”). Teagarden claims that in 2024, he made multiple public-records requests for 11 “separate and distinct public records” while incarcerated at PCI and that ODRC has not provided him with any of the requested items. {¶ 4} Teagarden submitted public-records requests for two items to the warden’s office at PCI:

2 January Term, 2026

• Item No. 1: On September 13, 2024, Teagarden sent an electronic kite1 requesting “[a] copy of the ODRC Master Records Retention Schedule.” Marilyn Coffey, a warden’s administrative assistant and public-information officer at PCI, informed Teagarden by responsive kite that a copy of the records-retention schedule was available for him to pick up from the education officer. Teagarden also made a request on September 30 for the “current ODRC Master Records Retention Schedule,” alleging that the previously produced schedule was outdated. Coffey informed Teagarden that the copy he was given “is the most recent and up to date retention schedule.” • Item No. 2: On October 6, Teagarden transmitted a public-records request by electronic kite, seeking the audio recording from his hearing before the Rules Infraction Board (“RIB”) in case No. PCI-24-000045. Coffey denied the request, stating that the audio recording “is not a public record.” Teagarden claims that he previously submitted a public-records request for this same audio recording on February 20 in his appeal of the RIB’s decision finding him guilty of a conduct violation.2 He claims that his appeal was decided without addressing his public-records request. {¶ 5} Teagarden transmitted public-records requests for nine other items to PCI’s library, using the prison’s electronic-kite system: • Item No. 3: On July 31, 2024, Teagarden requested the library’s “Table of Organization, which depicts the need for, and use of, [inmates] as library aides and legal services clerks” under ODRC Policy No. 58-LIB-02(VI)(C). The

1. “A kite is a type of written correspondence between an inmate and prison staff.” State ex rel. Griffin v. Szoke, 2023-Ohio-3096, ¶ 3.

2. The RIB determines the guilt of inmates who allegedly violate the inmate rules of conduct, see Adm.Code 5120-9-06, and it imposes penalties on inmates found guilty of a violation, see Adm.Code 5120-9-08 (A) and (B). An RIB decision is subject to two levels of appeal. See id. at (O) and (P).

3 SUPREME COURT OF OHIO

library denied the request, stating that it is “prohibited in giving [inmates] certificates or any certifications while incarcerated.” • Item No. 4: On August 5, Teagarden requested “copies of each of the individual Position Descriptions signed by the [inmates] working in the library” under ODRC Policy No. 58-LIB-02(VI)(C)(3). In response, the library informed Teagarden that it would provide him with unsigned copies of the position descriptions once he paid the copying cost for those records. • Item No. 5: On August 6, Teagarden requested “a copy of the Library Administrator’s Lesson Plan” as prepared by the library administrator under ODRC Policy No. 58-LIB-02(VI)(C)(4). The library denied the request, stating that it does not provide inmates with “staff related materials.” • Item No. 6: On August 7, Teagarden requested “a copy of the PCI Library Staff Lesson Plan” as prepared by library staff under ODRC Policy No. 58-LIB- 02(VI)(C)(4). The library denied the request, reiterating that “[s]taff-related materials are not given to [inmates].” • Item No. 7: On September 13, Teagarden requested “a copy of the written library procedure for circulation of materials, access to reference services, non print material, and reader advisory services to prisoners as set forth under [ODRC Policy No.] 58-LIB-01, VI(A)(2).” The library denied the request, stating that Teagarden was “not allowed to have this.” • Item No. 8: On September 15, Teagarden requested “a copy of the library’s monthly report per [ODRC Policy No. 58-LIB-01(VI)(D)(1)], for September 2024.” The library denied the request, telling Teagarden that he was “not allowed to have this.” • Item No. 9: On September 29, Teagarden requested “a copy of the Library’s written plan for the selection of incarcerated persons to work as library aides” as developed by the library staff under ODRC Policy No. 58-LIB-02(VI)(C)(2).

4 January Term, 2026

Despite Teagarden’s having sent his public-records request to the library, he received a response directing him to send his request to the library. Teagarden therefore sent another public-records request to the library on September 30 asking for the same record. The library directed Teagarden to review its responses to two prior requests he made for this record. • Item No. 10: On October 13, Teagarden requested “a copy of the library’s monthly report per [ODRC Policy No. 58-LIB-01(VI)(D)(1)], for October 2024.” The library notified Teagarden that he could visit the library and obtain a copy of the requested record upon paying the copying cost. • Item No. 11: On October 29, Teagarden requested a copy of a library sign displaying a rule limiting the amount of time that inmates may meet with certain library staff members each week.

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Bluebook (online)
2026 Ohio 567, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-teagarden-v-dept-of-rehab-corr-ohio-2026.