State ex rel. Davis v. Metzger
Annotate this CaseAppellant filed a public-records request under the Ohio Public Records Act for the personnel records of six employees of the West Licking Joint Fire District. Less than three business days later, Appellant filed a complaint for a writ of mandamus in the court of appeals. The district’s counsel completed the review of the requested records the same day, and the district sent the documents to Appellant that afternoon. The district did not become aware of Appellant’s complaint until the next day. The court of appeals concluded that the records were produced in a reasonable amount of time and that Appellant had engaged in frivolous conduct. The Supreme Court affirmed in part but found that the court of appeals abused its discretion when it failed to hold a show-cause hearing before finding that Appellant had engaged in frivolous conduct. On remand, the court of appeals held the required hearing and found that Appellant engaged in frivolous conduct, thus awarding attorney fees. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in finding that the continuation of unnecessary discovery after the requested records were provided was frivolous conduct.
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