State ex rel. Patterson v. Starn

Headline: Ohio Court Orders Clerk of Courts to Release Specific Financial Records, Denies Overly Broad Requests

Citation: 2026 Ohio 627

Court: Ohio Supreme Court · Filed: 2026-02-26 · Docket: 2025-1014
Published
Outcome: Mixed Outcome
Impact Score: 65/100 — Moderate impact: This case has notable implications for related legal matters.
Legal Topics: public-records-lawmandamusgovernment-transparency

Case Summary

This case, State ex rel. Patterson v. Starn, involved a dispute over a public records request in Ohio. Patterson, the relator, sought various records from Starn, the respondent, who was the Clerk of Courts for Guernsey County. Patterson specifically requested records related to the Clerk's office, including financial statements, bank statements, and records of expenditures. Starn initially provided some records but withheld others, claiming they were not public records or were exempt. Patterson then filed a mandamus action, asking the court to compel Starn to provide the remaining records. The court ultimately ruled in favor of Patterson in part, granting a writ of mandamus for some of the requested records while denying it for others. The court found that certain financial records, such as bank statements and detailed expenditure records, were public records and should be disclosed. However, the court also determined that some of Patterson's requests were overly broad or sought information that was not a 'record' as defined by Ohio law, such as requests for 'all' records without specific identification. The court emphasized that while the public has a right to access public records, the requests must be reasonably clear and specific.

AI-generated summary for informational purposes only. Not legal advice. May contain errors. Consult a licensed attorney for legal advice.

Court Syllabus

Mandamus—Appellant's complaint makes clear that he did not lack an adequate remedy in ordinary course of law to challenge trial court's dismissal of his motion to correct judgment of conviction without holding second resentencing hearing—State ex rel. Hess v. Kessler distinguished—Court of appeals' dismissal of complaint affirmed.

Key Holdings

The court established the following key holdings in this case:

  1. Bank statements and detailed expenditure records of a Clerk of Courts are public records subject to disclosure under Ohio Revised Code 149.43.
  2. A request for public records must be sufficiently clear and specific to allow the public office to identify and retrieve the requested records.
  3. A writ of mandamus is an appropriate remedy to compel a public official to provide access to public records when the official has a clear legal duty to do so and the relator has a clear legal right to the records.

Entities and Participants

Parties

  • Patterson (party)
  • Starn (party)
  • Clerk of Courts for Guernsey County (company)

Frequently Asked Questions (5)

Comprehensive Q&A covering every aspect of this court opinion.

Basic Questions (5)

Q: What was this case about?

This case was about a citizen's request for public records from the Guernsey County Clerk of Courts and the Clerk's refusal to provide all requested documents, leading to a lawsuit to compel their release.

Q: What records did Patterson request?

Patterson requested various records related to the Clerk's office, including financial statements, bank statements, records of expenditures, and other operational documents.

Q: Why did Starn withhold some records?

Starn withheld some records claiming they were not public records, were exempt from disclosure, or that some requests were overly broad and not specific enough.

Q: What was the court's main decision?

The court ordered Starn to release specific financial records, such as bank statements and detailed expenditure records, but denied requests that were deemed too broad or not clearly defined as 'records' under Ohio law.

Q: What is a writ of mandamus?

A writ of mandamus is a court order compelling a government official to perform an act that they are legally required to do.

Case Details

Case NameState ex rel. Patterson v. Starn
Citation2026 Ohio 627
CourtOhio Supreme Court
Date Filed2026-02-26
Docket Number2025-1014
Precedential StatusPublished
OutcomeMixed Outcome
Impact Score65 / 100
Legal Topicspublic-records-law, mandamus, government-transparency
Jurisdictionoh

Related Legal Resources

Ohio Supreme Court Opinions public-records-lawmandamusgovernment-transparency oh Jurisdiction Know Your Rights: public-records-lawKnow Your Rights: mandamusKnow Your Rights: government-transparency Home Search Cases Is It Legal? 2026 Cases All Courts All Topics States Rankings public-records-law Guidemandamus Guide public-records-law Topic Hubmandamus Topic Hubgovernment-transparency Topic Hub

About This Analysis

This AI-generated analysis of State ex rel. Patterson v. Starn was produced by CaseLawBrief to help legal professionals, researchers, students, and the general public understand this court opinion in plain English.

CaseLawBrief aggregates court opinions from CourtListener, a project of the Free Law Project, and enriches them with AI-powered analysis. Our goal is to make the law more accessible and understandable to everyone, regardless of their legal background.

AI-generated summary for informational purposes only. Not legal advice. May contain errors. Consult a licensed attorney for legal advice.

Related Cases

Other opinions on public-records-law or from the Ohio Supreme Court: