December 19, 2025
The Ohio Supreme Court has issued an important public-records decision clarifying when government agencies may—and may not—redact information from records produced under Ohio’s Public Records Act.
In State ex rel. Mauk v. Sheldon, the Court held that the Richland County Sheriff improperly redacted large portions of public-records request logs and related materials, and that those improper redactions amounted to unlawful denials of public-records requests.
Andrea Mauk submitted multiple public-records requests to the Richland County Sheriff’s Office following the death of her son. While the Sheriff did produce records, many were heavily redacted. The Sheriff claimed exemptions based on victim privacy, law-enforcement investigatory protections, and “personal notes.”
Mauk filed a mandamus action asking the Ohio Supreme Court to compel full disclosure and to award statutory damages, attorney fees, and costs.
The Supreme Court granted the writ in part, ordering the Sheriff to re-produce records responsive to three public-records requests with only Social Security numbers redacted.
The Court made several key rulings:
Improper use of exemptions: The Sheriff failed to prove that most of the redacted information fell within any lawful exemption under the Public Records Act.
Request logs are not investigatory records: Public-records requests themselves are not “law-enforcement records,” even if they seek law-enforcement information.
Victim-privacy claims require proof: Agencies must show that disclosure would create a high probability of endangering a victim’s life or safety. General assertions are not enough.
“Personal notes” must actually be personal: Notes kept in official files and accessible to other employees are not shielded simply by labeling them “personal.”
The Court confirmed that Social Security numbers are properly exempt, but little else was.
Because improper redactions are treated as denials under Ohio law, the Court awarded $2,000 in statutory damages. However, the Court declined to award attorney fees, concluding that although Mauk prevailed on some claims, she succeeded on only a small fraction of the total requests litigated.
In a notable partial dissent, Chief Justice Kennedy argued that attorney fees should have been awarded. She emphasized that public-records litigation is costly, that Mauk ultimately prevailed on multiple requests, and that courts can tailor fee awards to the portion of the case actually won.
The dissent underscored a recurring tension in public-records cases: enforcing transparency while ensuring citizens are not priced out of enforcing their rights.
Why This Decision Matters
This ruling sends a clear message to public agencies across Ohio. Redactions must be narrowly justified. Exemptions are not presumed—they must be proven. Over-redaction can carry financial consequences.
For citizens, journalists, and lawyers, the decision reinforces that the Public Records Act has teeth—and that courts will scrutinize claims of confidentiality closely.
Transparency, the Court reminded, is not discretionary. It is the rule.
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