Ohio Public-Records Mandamus Must Await Expiration of the Full Three-Business-Day Cure Period

1. Introduction

This decision clarifies an important procedural restriction on enforcing Ohio’s Public Records Act: a requester must allow the public office the entire statutory three-business-day cure period after receipt of a properly served pre-suit complaint before commencing a mandamus action. Filing a written affirmation of compliance does not overcome documentary evidence showing that the lawsuit was premature.

The dispute arose between Brian M. Ames, a self-represented public-records requester, and the West Geauga Local School District Board of Education. Ames sought an unredacted copy of the district’s February 2025 check register. The board produced the register but withheld student initials, asserting that disclosure would violate federal and Ohio student-privacy laws.

Although that disagreement raised potentially significant questions about educational privacy and access to financial records, the Supreme Court did not decide them. Instead, it affirmed dismissal because Ames filed suit before the statutory waiting period expired. The opinion also resolved 27 collateral motions, addressing sanctions, vexatious litigation, appellate records, finality, self-representation, and procedural irregularities.

2. Background and Procedural History

The records request and disputed redactions

On March 24, 2025, Ames emailed district treasurer Karen Pavlat requesting “the check register for February 2025.” Pavlat acknowledged the request that day. On April 3, board counsel Sara Ravas Cooper provided the register with student initials redacted.

The register described services purchased for particular students and identified those students through student numbers and initials. Counsel maintained that the Family Educational Rights and Privacy Act, 20 U.S.C. 1232g, commonly called FERPA, and the Ohio Student Privacy Act, R.C. 3319.321, prohibited disclosure of the initials in that context.

Ames disputed that position. On April 15, he asserted that directory information, including student names, was excluded from protected personally identifiable information and announced his intention to seek mandamus relief. These were the parties’ competing positions, not conclusions adopted by the Supreme Court.

The new pre-suit procedure

Amendments to R.C. 149.43, effective April 9, 2025, introduced a formal pre-suit complaint and cure procedure. On April 21, Ames sent the prescribed complaint to the board by certified mail. The signed receipt attached to his eventual petition recorded delivery on Monday, April 28.

On April 29, Pavlat informed Ames that the district had received the complaint and stood by its original response. Ames filed his mandamus petition in the Eleventh District Court of Appeals on April 30, seeking the unredacted register, statutory damages, attorney’s fees, and court costs.

Ames submitted an “affidavit of verity” asserting compliance with the statutory pre-suit requirements. His petition alleged service on April 25, but its attached certified-mail receipt showed April 28. The Eleventh District relied on that exhibit and dismissed the action as premature. It then denied all pending motions as moot, including the board’s motion for judgment on the pleadings.

3. Summary of the Opinion

The Supreme Court affirmed the dismissal. Its principal conclusions were:

• Review is de novo: whether the requester complied with R.C. 149.43(C)(1) presents a procedural-compliance question reviewed independently.
• The waiting period begins upon receipt: mailing the pre-suit complaint does not itself start the cure period.
• The receipt date is excluded: Civ.R. 6(A) governs the computation, leaving the public office three business days after receipt.
• Filing during the third business day is still premature: the action may begin only after that day expires.
• The appellate record controlled: the court declined to obtain additional USPS tracking information that Ames had not presented below.
• The underlying disclosure dispute remained unresolved: the court did not decide whether the student initials were properly redacted or whether Ames otherwise qualified for monetary relief.
• No collateral relief was granted: one motion was denied as moot, all other pending motions were denied, and both parties were warned against future motion-practice abuse.

Six justices joined the per curiam opinion. Chief Justice Kennedy concurred except as to Part II(B), concerning the statutory prerequisites, and Part II(C)(14), concerning the board’s proposed revised appendix. She dissented in part and would have reached the petition’s merits for the reasons expressed in her dissenting opinion in State ex rel. Jordan v. Dept. of Rehab. & Corr., 2025-Ohio-3051. Those reasons are not reproduced in the supplied opinion.

4. Legal Reasoning

A. The statute establishes a sequence of mandatory procedural steps

The court read R.C. 149.43(C)(1) and (2) together as imposing several distinct requirements before public-records litigation may proceed:

1. Proper service: the requester must serve the public office or records custodian with a pre-suit complaint on the form prescribed by the clerk of the Court of Claims, using service conforming to Civ.R. 4.
2. A complete cure period: following receipt, the office has three business days to cure or otherwise address the alleged failure.
3. No premature judicial filing: the requester “shall not” file a court complaint or commence mandamus during that period.
4. A contemporaneous written affirmation: the judicial complaint or petition must be accompanied by a statement affirming proper transmission, expiration of the required interval, and the absence of a satisfactory resolution.

The prescribed pre-suit complaint is therefore not merely an informal demand letter. Nor does its title mean that the requester has already commenced litigation in the Court of Claims. It is a preliminary service requirement that precedes the statutory litigation options.

The opinion separately identifies the written-affirmation requirement and the actual waiting requirement. Ames supplied an affirmation; his case nevertheless failed because the record showed that he had not waited long enough. The statute’s express command to dismiss a suit lacking an affirmation was not the operative defect here.

B. Receipt, rather than dispatch, starts the cure period

Ames mailed the pre-suit complaint on April 21, but the statute grants the office three business days “[u]pon receipt.” The court therefore used the receipt date established by the certified-mail exhibit, not the earlier mailing date.

This interpretation is important because R.C. 149.43(C)(2) describes the affirmation partly in terms of when the complaint was “transmitted.” That language does not displace the receipt-based cure period expressly established by R.C. 149.43(C)(1). Actual compliance requires allowing the office its statutory response interval after receipt.

C. The day of receipt does not count

Under Civ.R. 6(A), the triggering day is excluded when computing a statutory period. Consequently, the board’s receipt on Monday, April 28, produced the following schedule:

The court also supplied an independently sufficient alternative explanation. Even if delivery occurred on Friday, April 25, as Ames claimed, the three business days would have been April 28, 29, and 30. His April 30 petition would still have been premature; the earliest permissible filing date on that premise would have been May 1.

The decisive distinction is between filing on the third business day and filing after the three-business-day period. The statute permits only the latter.

D. The board’s rejection did not change the outcome

The board reaffirmed its position on April 29, before the cure period expired. The court nevertheless enforced the complete waiting period. As applied, an early response maintaining the challenged redactions did not make Ames’s April 30 filing permissible.

The opinion does not separately develop a waiver or futility doctrine. Its narrower significance is that the court applied the statutory prohibition despite the board’s intervening statement that it would stand by its response.

E. The appeal could not become a new evidentiary proceeding

Ames asked the Supreme Court to visit the USPS website and use the certified-mail tracking number to verify an asserted April 25 delivery. That tracking information had not been presented to the Eleventh District.

The Supreme Court declined the request because direct appellate review is confined to the record below. Calling the request one for judicial notice did not persuade the court to obtain new factual material and decide the appeal on that basis. The certified-mail receipt already in the record therefore controlled over the petition’s inconsistent allegation.

The court applied the same record discipline to the board. It declined to consider improper material placed in the board’s merits appendices and refused to supplement the merits record with postjudgment docket entries unrelated to the questions presented. This treatment of the merits record should be distinguished from the court’s separate assessment of materials submitted in support of motions alleging sanctionable appellate conduct.

F. Procedural noncompliance did not make the judgment jurisdictionally void

The board argued that the Eleventh District lacked jurisdiction and that its dismissal was therefore void. The Supreme Court rejected that characterization. The lower court had dismissed for failure to comply with statutory procedural requirements, not for lack of subject-matter jurisdiction.

The Ohio Constitution independently gives courts of appeals original jurisdiction in mandamus, and the Supreme Court had appellate jurisdiction over the resulting judgment. The decision thus distinguishes a court’s authority to hear a category of cases from a particular litigant’s failure to satisfy a mandatory prerequisite.

This reasoning does not establish that every statutory precondition is necessarily nonjurisdictional. It resolves the board’s specific attempt to convert the dismissal here into a void judgment.

G. The decision is procedural, not a student-privacy ruling

The court did not decide whether student initials were protected under FERPA or the Ohio Student Privacy Act, whether directory-information principles required disclosure, or whether connecting students to purchased services changed the analysis. It also did not determine whether the original production was sufficiently prompt.

Accordingly, the opinion cannot properly be cited as approving the redactions. The board prevailed because the suit was premature, not because the court endorsed its substantive interpretation of student-privacy law.

5. Precedents Cited and Their Influence

A. Standard of review and statutory prerequisites

State ex rel. Woods v. Heekin, 2024-Ohio-1719, ¶ 8

This decision supplies the de novo standard for reviewing dismissal of a mandamus action under Civ.R. 12(B)(6). It supported independent review here, although the Supreme Court did not characterize the lower court’s disposition simply as a dismissal under that rule.

State ex rel. Duncan v. Mentor, 2023-Ohio-3115, ¶ 6

This case establishes de novo review of a Civ.R. 12(B)(1) dismissal for lack of subject-matter jurisdiction. It furnished another procedural analogy; its citation did not mean that the court considered Ames’s statutory noncompliance jurisdictional.

McIntyre v. May, 2026-Ohio-1231, ¶ 5

The court treated this as the closest analogy. It applies de novo review to dismissal of an extraordinary-writ action for failure to comply with R.C. 2969.25(A). Because both statutes require assessment of procedural compliance, the same standard governed Ames’s appeal.

State ex rel. Jordan v. Dept. of Rehab. & Corr., 2025-Ohio-3051

The majority quoted Justice DeWine’s concurrence, paragraph 4, for the proposition that compliance with the new pre-suit requirement is a prerequisite to commencing litigation. The source matters: the quoted passage came from a concurrence, while the present opinion expressly adopts the mandatory-prerequisite reasoning.

The case also supplied Chief Justice Kennedy’s stated basis for dissenting from the refusal to reach the merits. Because the supplied opinion does not reproduce her earlier reasoning, no more specific account of that disagreement can reliably be drawn from this text alone.

B. Limits on the appellate record

Morgan v. Eads, 2004-Ohio-6110, ¶ 13

The court relied on this case’s “bedrock principle” that an appellate court is limited to the record of the proceedings below. It directly supported declining to investigate the USPS tracking information.

State v. Ishmail, 54 Ohio St.2d 402 (1978), paragraph one of the syllabus

This authority prohibits a reviewing court from adding material that was not before the lower court and then deciding the appeal on that new material. It reinforced the distinction between reviewing the existing record and developing a new factual basis on appeal.

C. Sanctions and vexatious litigation

State ex rel. Striker v. Cline, 2011-Ohio-5350, ¶ 12-15

Cited alongside the statutory definition of frivolous conduct, this case supported the governing categories under R.C. 2323.51: improper-purpose litigation, legally unwarranted positions, unsupported factual assertions, and unwarranted factual denials. The board still had to establish qualifying conduct rather than merely identify an unsuccessful lawsuit.

State ex rel. Haley v. Davis, 2016-Ohio-534, ¶ 16

This case establishes that Civ.R. 11 sanctions require a willful violation. It defeated Ames’s effort to sanction board counsel for an allegedly incorrect service date. The documentary record supported counsel’s stated date, and Ames supplied no evidence of intentional misconduct even assuming an error had occurred.

State ex rel. Johnson v. Bur. of Sentence Computation, 2020-Ohio-999, ¶ 20-23

This precedent involved 22 original actions over approximately seven years, together with repetitive arguments and duplicative proceedings. Its importance was qualitative as well as numerical: vexatiousness depended on repeatedly pursuing rejected arguments, not simply filing many cases.

State ex rel. Ware v. Vigluicci, 2024-Ohio-5492, ¶ 10-12

This case demonstrates that persistent frivolous conduct within one case can justify a vexatious-litigator declaration. Fabricated evidence, false statements, and continued reliance on fraudulent documents supplied concrete misconduct absent from the board’s showing against Ames.

State ex rel. Ames v. Geauga Cty. Bd. of Dev. Disabilities, 2024-Ohio-5441 (11th Dist.)

The board offered this decision to support its initial vexatious-litigator motion. But the cited case affirmed dismissal of a complaint for declaratory and injunctive relief. It did not substantiate the board’s broader allegation of habitual, groundless mandamus litigation.

State ex rel. Hill v. Navarre, 2020-Ohio-4274, ¶ 13, 16

The litigant repeatedly attacked criminal convictions through duplicative extraordinary-writ proceedings and arguments already rejected. This illustrated the specific repetitive misuse that can establish frivolous conduct under S.Ct.Prac.R. 4.03(A) and (B).

State ex rel. M.D. v. Kelsey, 2023-Ohio-2165, ¶ 11-12

Repeated appeals from nonfinal orders and a disqualification affidavit were used to prevent proceedings from reaching final hearings and to obstruct compliance with a writ of procedendo. The case supplied an example of demonstrable delay tactics, rather than an inference drawn from unfavorable outcomes alone.

State ex rel. Tingler v. Franklin Cty. Prosecutor’s Office, 2023-Ohio-640, ¶ 4-5

The court cited Justice Fischer’s concurrence, which considered numerous meritless cases, nearly identical language, repeated issues, and improper requests for grand-jury materials. The separate-opinion source is significant: it illustrated relevant considerations without making numerical volume alone determinative.

D. Sanctions requests, pleadings, and appellate finality

S & S Computer Sys., Inc. v. Peng, 2002-Ohio-2905, ¶ 10, fn. 1 (9th Dist.)

This case distinguishes a sanctions motion from a claim for relief in a pleading. It supported the conclusion that the board could not create an unresolved sanctions motion merely by placing a demand for sanctions in its answer.

Haney v. Trout, 2002-Ohio-564, 2002 WL 205997, *6 (10th Dist. Feb. 12, 2002)

This decision likewise rejects treating a sanctions motion as a pleading. The court used it to reinforce the separate procedural requirements of Civ.R. 7(A) and 7(B).

Riston v. Butler, 2002-Ohio-2308, ¶ 24 & fn. 20 (1st Dist.)

This citation qualified the preceding authority by noting that it had been superseded by statute on other grounds. It was not an independent basis for deciding Ames’s appeal, but identified a limitation on the cited precedent’s subsequent history.

State ex rel. Verhovec v. Marietta, 2013-Ohio-5414, ¶ 84 (4th Dist.)

The board relied on this case because a dismissal there left unresolved an already-filed motion for statutory damages, costs, and attorney’s fees. The Supreme Court distinguished it: the board’s relevant sanctions motions here were filed after judgment. The decision therefore did not establish that those later motions destroyed the dismissal’s finality.

E. Appellate briefing, corrective filings, and oral argument

Drake v. Bucher, 5 Ohio St.2d 37, 40 (1966)

This authority supplied both sides of the court’s approach to procedural rules: substantial disregard cannot be tolerated, but some liberality is appropriate. The court declined to strike briefs for shortcomings that did not impair an opponent’s response or judicial resolution.

State ex rel. Sultaana v. Mansfield Corr. Inst., 2023-Ohio-1177, ¶ 13

This case supported denying motions to strike technically deficient briefs when the deficiencies caused no relevant prejudice. It informed the court’s treatment of both Ames’s incomplete appendix and the board’s noncompliant submissions.

State ex rel. Physicians Commt. for Responsible Medicine v. Ohio State Univ. Bd. of Trustees, 2006-Ohio-903, ¶ 14

The court drew the same practical principle from this decision: a brief need not be struck when the opposing party can respond and the court can adjudicate the case despite its shortcomings.

State ex rel. Morgan v. New Lexington, 2006-Ohio-6365, ¶ 26

This case recognizes broad judicial discretion over motions to strike. It supported disregarding improper material rather than removing entire portions of the board’s filings.

State ex rel. Mun. Constr. Equip. Operators’ Labor Council v. Cleveland, 2020-Ohio-3197, ¶ 19

The court cited this decision as an example of declining to consider an affidavit supporting an argument first raised on appeal. Its influence was remedial: improper material can be ignored without granting a motion to strike.

Golub v. Werren, 2025-Ohio-2950, ¶ 13

This contrasting authority involved sua sponte striking documents outside the appellate record. Its inclusion shows that striking remains available, but is not mandatory whenever improper appendix material appears.

State ex rel. Slager v. Trelka, 2024-Ohio-5125, ¶ 10

The court had allowed a revised merit brief when the request was unopposed and caused no prejudice. That procedural setting differed from the board’s opposed request to revise an appendix after Ames filed his reply.

State ex rel. Siebold v. Columbus City Schools Bd. of Edn., 2025-Ohio-5245, ¶ 15

This decision similarly permitted revised evidence under nonprejudicial, unopposed circumstances. It illustrated favorable conditions for revision rather than establishing an entitlement to late amendment.

State ex rel. Boddy v. Xenia Community City School Dist. Bd. of Edn., 2026-Ohio-164, ¶ 10, 14

The court contrasted a denied revision request that was opposed and would prejudice a party that had already briefed the case. Here, prejudice was uncertain, but briefing had concluded and the board identified no authority requiring permission. The opinion did not create an absolute rule that opposition alone defeats revision.

State ex rel. Ruble v. Switzerland of Ohio Local School Dist. Bd. of Edn., 2025-Ohio-1510, ¶ 10

This case identifies the circumstances generally supporting oral argument in direct appeals: great public importance, complex factual or legal issues, substantial constitutional questions, or appellate conflict. The board did not substantiate its claim of public importance, and the briefs adequately presented the issues.

F. Mandamus captions and related proceedings

Litigaide, Inc. v. Custodian of Records for Lakewood Police Dept., 1996-Ohio-205, ¶ 2

This case establishes that failing to bring mandamus in the State’s name can warrant dismissal. It defeated the board’s theory that Ames practiced law without authorization by using the required caption: compliance with R.C. 2731.04 did not transform self-representation into representation of the State.

State ex rel. Ames v. W. Geauga Local School Dist. Bd. of Edn., 2026-Ohio-2248, ¶ 7-12 (11th Dist.)

This separate proceeding concerned a different request and email service of a pre-suit complaint. The Eleventh District held that email did not satisfy Civ.R. 4.1 and that the cure period had therefore never begun. The Supreme Court discussed that decision to explain why consolidation was inappropriate, not to decide the separate appeal’s service issue.

6. The Collateral Rulings

A. Losing a case is not itself sanctionable

The board repeatedly sought sanctions against Ames, while Ames sought sanctions against board counsel. The court granted neither side relief.

The applicable standards remained distinct. S.Ct.Prac.R. 4.03(A) permits sanctions for frivolous filings or filings prosecuted for delay, harassment, or another improper purpose. Civ.R. 11 requires a willful violation. The court repeatedly assumed, without deciding, that Civ.R. 11 applied in the Supreme Court appeal. It did not definitively resolve that applicability question.

R.C. 149.43(C)(6) authorizes the court in which the public-records mandamus action was brought to sanction frivolous commencement of that action. Because Ames filed in the Eleventh District, that court was the proper forum for such a request concerning the original action.

The board’s recurring reliance on defeat, disagreement, and asserted impropriety did not establish the necessary misconduct. The court also rejected the contention that an allegedly false footnote about legal expenses in CATA v. Auburn Career Center required sanctions, striking, or a hearing. That reference was a disputed factual statement, not precedent supporting the decision. The court did not determine its truth and emphasized that Ames’s response otherwise presented legitimate opposition to consolidation.

B. Litigation volume does not establish vexatiousness without more

The board submitted a history of 64 actions or appeals filed by Ames in the Supreme Court since 2016 and asserted that approximately 95 percent were frivolous. The court did not accept that inference.

The decisive omission was a supported connection between the listed proceedings and abusive conduct. The board did not demonstrate repetitive presentation of already-rejected arguments, proceedings calculated to delay, or dishonesty in a specific case. A large docket and frequent lack of ultimate relief were insufficient by themselves.

At the same time, the court preserved its ability to act against genuine abuse. Its precedents recognize both repetitive misconduct across cases and persistent dishonesty within a single proceeding as possible grounds for a vexatious-litigator declaration.

C. A sanctions demand in an answer is not a sanctions motion

The board argued that its demand for sanctions, embedded in its answer, remained unresolved and prevented a final appealable judgment. The court rejected that premise.

Civ.R. 7 separates pleadings from motions. An application for a court order must be made by motion, and both Civ.R. 11 and R.C. 2323.51 specifically contemplate motions. Including a sanctions request among “additional defenses” did not satisfy that procedure.

The board also failed to show that its postjudgment sanctions motions deprived the earlier dismissal of finality. Nor could it obtain remand under App.R. 4: the Rules of Appellate Procedure govern appeals to courts of appeals, while Supreme Court appeals are governed by the applicable Supreme Court Rules of Practice.

D. A self-represented relator does not represent the State as a lawyer

The board argued that Ames, a nonlawyer, engaged in unauthorized practice by prosecuting a case formally brought in the State’s name. The court rejected that argument as “nonsensical.”

R.C. 4705.01 prohibits unauthorized representation in proceedings in which the person is not a party concerned. Ames was the requester and the person claiming injury from noncompliance; he was therefore a real party in interest. R.C. 2731.04 required the State-on-relation caption.

A later letter stating that an unauthorized-practice complaint lacked sufficient credible supporting evidence was unnecessary to this conclusion. The court denied leave to add it because the outside complaint’s disposition was immaterial to the asserted jurisdictional issue.

E. Technical irregularities and mandatory prerequisites received different treatment

The court tolerated certain briefing and service-certificate imperfections where they did not cause prejudice or prevent decision. It refused, however, to excuse filing before expiration of an expressly mandatory statutory period.

For example, Ames’s certificate identified board counsel as counsel for another entity, but correctly named the lawyer and used the proper email address. Service on counsel of record had occurred, so the descriptive error did not justify striking the response.

This distinction is central: procedural flexibility concerning the presentation of an appeal does not authorize disregard of a statutory prohibition on commencing the action.

F. Disposition of all 27 pending motions

The court closed by warning both parties that future unnecessary and groundless motions could produce sanctions. Its refusal to impose sanctions here was not approval of their motion practice.

7. Potential Impact

A. Greater emphasis on pre-filing verification

Requesters must document proper service, establish receipt, exclude the triggering date, and wait through all three business days. A correct form and a sworn assertion of compliance cannot substitute for an accurately calculated filing date.

The decision does not establish that dismissal must be with prejudice or determine the availability of refiling. Its practical lesson is to avoid the defect before filing rather than assume the passage of time during litigation will cure it.

B. Procedural dismissal may prevent development of substantive access law

A potentially consequential dispute over student identifiers and school financial records received no merits determination. Future litigants seeking clarification of public-records exceptions must first satisfy the statutory gateway.

The three-business-day rule should not be confused with a universal deadline for responding to an initial records request. It governs the office’s opportunity to address a formally served pre-suit complaint; it does not replace the Public Records Act’s underlying production obligations.

C. Sanctions applicants need case-specific proof

Parties seeking sanctions or filing restrictions should identify the particular unsupported contention, repeated rejected argument, fabricated material, or delay mechanism involved. A list of losses is not a substitute for that analysis.

This approach preserves meaningful access to judicial review while leaving courts able to restrain demonstrable abuse. It also warns public offices that defending against prolific requesters does not excuse unsupported collateral motions.

D. Appellate restraint operates in both directions

Neither a requester nor a public office may use merits appendices, online searches, or irrelevant postjudgment filings to reconstruct the factual case on appeal. At the same time, courts retain discretion to disregard improper material rather than allow motions to strike to dominate the litigation.

E. Self-representation remains available in public-records mandamus

The decision rejects an argument that would have obstructed nonlawyer requesters merely because mandamus uses the State’s name. A requester pursuing personal statutory rights remains a party concerned, notwithstanding the formally required caption.

8. Complex Concepts Simplified

Mandamus

A court order requiring a public office or official to perform a legal duty. Here, Ames wanted an order compelling production of an unredacted record.

Relator and “ex rel.”

The relator is the person seeking the writ. “Ex rel.” means “on the relation of”: the case uses the State’s name but is initiated by the person asserting the right.

De novo review

The appellate court decides the legal question independently, without deferring to the lower court’s conclusion. This does not authorize collecting new evidence.

Cure period

A statutory opportunity to correct or address an alleged failure before litigation begins. Here, the office receives three business days after receipt of the prescribed complaint.

Subject-matter jurisdiction

A court’s authority to hear a category of disputes. A party can fail a mandatory procedural requirement even though the court has jurisdiction over that category.

Final appealable order

A judgment sufficiently complete to permit appellate review. The board did not show that its sanctions demands prevented the dismissal from qualifying.

Frivolous and vexatious litigation

Frivolous litigation lacks the required factual or legal foundation or serves an improper purpose. Vexatious litigation involves habitual or persistent qualifying abuse, not merely frequent unsuccessful filing.

Moot motion

A motion that no longer presents a live issue. Ames’s challenge to an earlier motion became moot when a revised version superseded it.

9. Conclusion

The principal holding is precise: a public-records requester must wait until the entire three-business-day cure period has expired, calculated from receipt of the properly served pre-suit complaint and excluding the receipt date. Ames’s petition was premature under either proposed delivery date.

The opinion also draws important boundaries. Procedural noncompliance does not automatically render a judgment jurisdictionally void; frequent litigation does not alone establish vexatiousness; and the required State-on-relation caption does not prevent self-representation. Above all, the decision resolves access to the courthouse—not the disputed student-privacy exception—and cautions both sides against allowing collateral motion practice to overwhelm the underlying controversy.