White v. Ross Corr. Inst.

2025 Ohio 2884
CourtOhio Court of Claims
DecidedJuly 22, 2025
Docket2025-00474PQ
StatusPublished

This text of 2025 Ohio 2884 (White v. Ross Corr. Inst.) is published on Counsel Stack Legal Research, covering Ohio Court of Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
White v. Ross Corr. Inst., 2025 Ohio 2884 (Ohio Super. Ct. 2025).

Opinion

[Cite as White v. Ross Corr. Inst., 2025-Ohio-2884.]

IN THE COURT OF CLAIMS OF OHIO

DONNA M. WHITE Case No. 2025-00474PQ

Requester Special Master Todd Marti

v. REPORT AND RECOMMENDATION

ROSS CORRECTIONAL INSTITUTION (RCI)/ OHIO DEPARTMENT OF CORRECTIONS

Respondent

{¶1} This case is before me for a R.C. 2743.75(F) report and recommendation. I recommend that the court (1) deny respondent’s motion to dismiss; (2) order respondent to take the actions listed in the appendix to this report and recommendation within 30 days of the entry of a judgment adopting this report and recommendation; (3) order respondent to file and serve an affirmation that it took those actions within 40 days of the entry of a judgment on this report and recommendation; (4) find that respondent unreasonably delayed its response to the public records requests underlying this case; (5) order respondent to pay requester’s filing fee, her costs, and the balance of the costs of this case; and (6) deny all other relief.

I. Background.

{¶2} Requester Donna White’s son died while he was in the custody of the respondent Ohio Department of Rehabilitation and Correction (“ODRC”). He was found to be non-responsive around 12:00 a.m. on July 23, 2024. ODRC staff called for an ambulance to take him to a local hospital, and administered Narcan and CPR during the approximately 25 minutes that elapsed before the ambulance arrived. The EMTs and medical professionals at the hospital made continued efforts to revive him, but he was pronounced dead at 12:56 a.m. PQ Miscellaneous, Respondent’s Material provided to Case No. 2025-00474PQ -2- REPORT AND RECOMMENDATION

Requester, filed June 16, 2025 (“Redacted Records”), pp. 5-18; Respondent Ross Correctional Institution (RCI)/Ohio Department of Rehabilitation and Correction’s Supplemental Unredacted Material, filed July 11, 2025 (“In Camera Records”), pp. 8-10, 13, 17. {¶3} Ms. White made multiple public records requests to ODRC for recordings of activities in the prison where he was housed, copies of her son’s medical records, and for information about ODRC staff and other inmates who interacted with her son. Those requests were made in October of 2024 and reiterated in April of 2025. ODRC produced some records in January, March, and April of 2025, but did not complete its response until mid-July of 2025. ODRC redacted some of those records and withheld others based on asserted exemptions from the Public Records Act. PQ Miscellaneous, Respondent’s presentation of evidence, filed June 16, 2025 (“Respondent’s Evidence”), pp. 3-46; Order, entered July 8, 2025. {¶4} Ms. White filed this case on May 12, 2025. Mediation was bypassed because of how long her requests had been pending and a schedule was set for filing records for in camera review and for the parties to file evidence and memoranda supporting their positions. That schedule, as modified, has run its course, making this case ripe for decision. Complaint, filed May 12, 2025; Order Bypassing Mediation, entered May 16, 2025; Order, entered June 3, 2025; Order, entered July 8, 2025.

II. Analysis. {¶5} Ms. White’s complaint alleges that ODRC improperly denied some of her records requests, that its responses to other requests were deficient in various ways, that it failed to provide legal bases for its denials, and that ODRC unreasonably delayed its response to her requests. {¶6} ODRC has not meaningfully addressed those allegations. It instead offers the procedural defense that Ms. White’s complaint should be dismissed due to her supposed failure to comply with R.C. 149.43(C)(2) and largely unexplained evidentiary submissions. Respondent Ross Correctional Institution (RCI)/Ohio Department of Rehabilitation and Correction’s Motion to Dismiss, filed June 26, 2025 (“MTD”); Respondent Ross Correctional Institution (RCI)/Ohio Department of Rehabilitation and Correction’s Presentation of Evidence, filed June 16, 2025 (“Respondent’s Evidence”). Case No. 2025-00474PQ -3- REPORT AND RECOMMENDATION

A. The court should deny respondent’s motion to dismiss because requester has complied with R.C. 149.43(C)(2). {¶7} R.C. 149.43(C)(1) requires a party contemplating suit under the Public Records Act to serve the public office with a complaint form outlining the violation(s) it asserts. It also requires the party to wait at least three business days before filing suit. That requirement is enforced by R.C. 149.43(C)(2): Upon filing a complaint or mandamus action . . . a person allegedly aggrieved shall file with the court, in conjunction with the person’s complaint or petition, a written affirmation stating that the person properly transmitted a complaint to the public office or person responsible for public records, the failure alleged in the complaint has not been cured or otherwise resolved to the person’s satisfaction, and that the complaint was transmitted to the public office or person responsible for public records at least three business days before the filing of the suit. If the person fails to file an affirmation pursuant to this division, the suit shall be dismissed. {¶8} Ms. White attempted to comply with R.C. 149.43(C)(2) by including the following language in her R.C. 2743.75 complaint: I affirm that a copy of this complaint was properly transmitted to the public office or person responsible for public records, that they were provided three business days to cure or otherwise address the failure alleged in this complaint, and that the failure alleged in the complaint has not been cured or otherwise resolved. Complaint, p. 1.1 {¶9} ODRC does not dispute Ms. White’s compliance with R.C. 149.43(C)(1) requirements, but seeks dismissal because, in its view, she has failed to comply with R.C. 149.43(C)(2) in two respects. It first contends that she has not made a proper “affirmation” because her affirmation was not made under oath. It also contends that her affirmation was procedurally deficient because it was made in her complaint, rather than in a separate filing. {¶10} The argument that Ms. White’s affirmation was deficient because it was not made under oath ignores R.C. 3.20. That statute unambiguously states that “[a]n affirmation has the same effect as an oath.” {¶11} The argument that Ms. White’s affirmation doesn’t count because it was not made in a separate pleading also ignores statutory text. R.C. 149.43(C)(2) requires that

1 All references to specific pages of the Complaint are to the pages of the PDF copy

posted on the court’s docket. Case No. 2025-00474PQ -4- REPORT AND RECOMMENDATION

the affirmation be made “in conjunction with . . . the complaint or petition.” The phrase “in conjunction with” is commonly understood to mean “together with” or “done . . . together.” Merriam-Webster Dictionary; Collins Dictionary;2 Collins Dictionary.3 The courts give the phrase a similar meaning. Young v. Young, 106 Ohio App. 206, 209 (12th Dist.1958) (“the state of being joined together,” “combination”). Including the R.C. 149.43(C)(2) affirmation in the complaint is placing them “together,” a “joining” and a “combination” of the affirmation and complaint and hence their being “in conjunction with” each other. {¶12} Finally, Supreme Court’s precedent counsels against ODRC’s construction of R.C. 149.43(C)(2). The Court “construe[s] R.C. 149.43 liberally in favor of broad access, with any doubt resolved in favor of disclosure of public records.” State ex rel. Morgan v. City of New Lexington, 2006-Ohio-6365, ¶ 28 (emphasis added). That cuts against ODRC’s strained construction. Further, that construction would needlessly complicate cases brought under R.C. 2743.75, a statute intended to provide a process for those not schooled in law. Welsh-Huggins v. Jefferson Cty. Prosecutor’s Office, 2020- Ohio-5371, ¶ 12.

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Bluebook (online)
2025 Ohio 2884, Counsel Stack Legal Research, https://law.counselstack.com/opinion/white-v-ross-corr-inst-ohioctcl-2025.