State ex rel. Payne v. Rose
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The Supreme Court denied mandamus relief in this action brought under Ohio's Public Records Act, Ohio Rev. Code 149.43, by Kevin Payne against Kelly Rose, an inspector at the Richland Correctional Institution (RCI), holding that Payne did not have a cognizable claim in mandamus.
Payne, an inmate at RCI, sent a public-records request to Rose for a copy of, among other things, JPay support ticket number MACI 1220002928. Rose responded that she obtained the requested record and provided a copy of it to Payne. Payne brought this action seeking a writ of mandamus ordering Rose to produce the requested record and statutory damages. The Supreme Court denied mandamus relief, holding (1) because Payne received his requested record before instituting this action he never had a cognizable claim in mandamus; and (2) statutory damages did not accrue.
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