Reasonable Response Time Under Ohio’s Public Records Act in High-Volume Contexts

Introduction

In State ex rel. Robinson v. Wesson, Slip Opinion No. 2025-Ohio-1874 (May 28, 2025), the Supreme Court of Ohio addressed the core question of what constitutes a “reasonable period of time” under R.C. 149.43(B)(1) when a public-information officer receives a large volume of public records requests from a single requester. Relator Jackie N. Robinson, an inmate at Grafton Correctional Institution (GCI), filed six consecutive electronic “kites” seeking copies of previously submitted filings. Despite acknowledging receipt of each request within days, respondent James Wesson did not deliver the requested copies until approximately three months later, amid over 50 requests seeking more than 300 documents. Robinson sought a writ of mandamus compelling production and statutory damages; the Court denied mandamus as moot and declined to award damages, holding that the delay was reasonable under the circumstances.

Summary of the Judgment

Mandamus Claim: Moot. Wesson ultimately produced all requested records, rendering relief by mandamus unnecessary.
Statutory Damages: Denied. Although Robinson’s public-records requests were clear and timely delivered, the Court found that responding within three months to six requests—amid over 50 requests for 300+ documents—was a “reasonable period of time” under R.C. 149.43(B)(1).
Pending Motions: All of Robinson’s procedural motions (to strike evidence, to proceed to judgment, for proof of service, etc.) were denied or overruled.
Concurrence/Dissent: Chief Justice Kennedy concurred in part (mandamus mootness and procedural rulings) and dissented in part (would have awarded statutory damages, arguing three months was unreasonably long for identifiable, unredacted kites).

Analysis

1. Precedents Cited and Their Influence

State ex rel. Physicians Committee v. Ohio State Univ. Bd. of Trustees, 2006-Ohio-903: Confirmed that writ of mandamus is the proper vehicle to compel compliance with the Public Records Act.
Consumer News Services, Inc. v. Worthington City Board of Education, 2002-Ohio-5311: Found a six-day delay unreasonable where only a few undisputed, unredacted records were requested.
Cincinnati Enquirer v. Pike County Coroner’s Office, 2017-Ohio-8988: Upheld a two-month turnaround for voluminous and redacted investigative records.
Shaughnessy v. Cleveland, 2016-Ohio-8447: Deemed a 31-business-day response reasonable where 345 pages required search, retrieval, and redaction—and the requester filed repeated large requests.
Beacon Journal Publishing Co. v. Andrews, 48 Ohio St.2d 283 (1979): Emphasized that excuses of high cost or interference cannot excuse unreasonable delays.

These precedents establish the framework for assessing “reasonableness”: scope of request, volume of records, need for redaction, existing workload due to multiple requests from the same party, and whether public-record–law duties were acknowledged and met.

2. Legal Reasoning Applied by the Court

Under R.C. 149.43(B)(1), a records custodian “shall make copies of the requested public record available . . . within a reasonable period of time.” The Court distilled the reasonableness factors:

Clarity and specificity of the requester’s description.
Volume and complexity of the records.
Effort required to locate, retrieve, and—if necessary—redact.
Concurrent demands on the custodian from the same requester.

Here, although Robinson’s six requests were precise (identifying 29 one- to two-page kites), Wesson testified—and submitted uncontested evidence—that between May and September 2024 he received over 50 separate public-records requests from Robinson, seeking more than 300 distinct documents. The Court concluded that three months to process six of those requests fell within a “reasonable period” in light of the aggregate workload and institutional constraints.

3. Mootness of the Mandamus Claim

Once a records custodian fully satisfies a requester’s demands before final resolution, the mandamus claim becomes moot. State ex rel. Brinkman v. Toledo City School Dist. Bd. of Edn., 2024-Ohio-5063, ¶ 25. Robinson acknowledged receipt of all kites by early September 2024, hence no live controversy remained.

4. Denial of Statutory Damages

Under R.C. 149.43(C)(2), a requester may recover up to $1,000 per request if the custodian “failed to comply” with a records-production duty. The Court held that because Wesson did comply—just within three months, not days—statutory damages were unwarranted. The controlling factor was the high aggregate volume of inmate requests to Wesson over a short span.

5. Impact on Future Cases

This decision clarifies that custodians can take “reasonable” time measured in months—rather than days—when faced with large, repetitive public-records requests by the same individual. Future courts will balance the request volume and custodian capacity against the requester’s statutory entitlement to prompt disclosure. Requesters should anticipate that high-volume contexts may justify longer delays without entitling them to damages.

Complex Concepts Simplified

Mandamus: A court order compelling a public official to perform a legal duty—in this case, to provide public records.
Mootness: When an issue no longer presents a live dispute—e.g., records were provided before final decision—courts dismiss the claim.
Statutory Damages: A fixed monetary award (up to $1,000/request) for unreasonable delays in producing public records when all other conditions (clear request, duty admitted) are met.
Reasonable Period of Time: A fact-dependent standard considering request complexity, volume, necessity of redactions, and the custodian’s overall workload.

Conclusion

State ex rel. Robinson v. Wesson establishes that in Ohio’s Public Records Act regime, a months-long delay may still fall within a “reasonable period of time” if a single requester’s exceptionally high volume of demands strains the custodian’s capacity. By denying statutory damages, the Supreme Court underscores that compliance—albeit delayed—is compliance. Custodians and requesters alike must now plan for the possibility that when dozens of requests for hundreds of documents inundate an office, response times measured in months can satisfy the statute’s reasonableness requirement.