State ex rel. Mothers Against Drunk Drivers v. Gosser

20 Ohio St. 3d 30 · Ohio Supreme Court · 1985

Facts

Appellants sought access to documents A-E, related to DWI cases, from the Clerk of the Miami County Municipal Court. The Clerk refused, citing a local court rule that created separate public and non-public files, effectively restricting access to these records.

Issue

Can a writ of mandamus compel the Miami County Municipal Court Clerk to provide access to documents related to DWI cases, which are considered public records, when a local court rule restricts their public availability?

Holding

Yes, the writ of mandamus is allowed. The court reversed the court of appeals' judgment, finding the documents are public records and the Clerk has a clear legal duty to make them available, invalidating the conflicting local rule.

Rule

Mandamus requires a clear legal right, a clear legal duty, and no adequate remedy at law. Public records are those required by law for a governmental unit's proper functioning, and local court rules cannot conflict with state statutes regarding public access to such records.

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Case brief last reviewed 2026-01-16. Prepared by CaseReader from the published opinion.