COLUMBUS, Ohio — The Ohio Supreme Court has ruled that the Ohio Department of Rehabilitation and Correction must pay an inmate $1,000 for failing to provide him with a copy of an inmate handbook, despite his repeated requests.
The court’s decision found that Lebanon Correctional Institution officials wrongfully delayed fulfilling Patrick Adkins’ request for records, violating Ohio’s public records law. Adkins, who was incarcerated at Lebanon Correctional from August 2023 to July 2024, initially sought access to the handbook in December 2023 but was denied by prison staff.
Inmate repeatedly denied access to handbook
According to court documents, Adkins submitted an electronic kite—a written communication between inmates and staff—asking to inspect and obtain a copy of the Lebanon Correctional Institution’s inmate handbook, which outlines prison policies and procedures.
Prison staff denied the request the same day, arguing that the handbook was considered an inmate record and was exempt from public disclosure under Ohio law. The prison’s public information officer, Ellen Myers, advised Adkins that he could speak with his unit staff to access a copy. However, Adkins later stated that his unit did not have a handbook available.
Over the following months, Adkins continued seeking access to the handbook, submitting additional requests in April 2024. When his requests were ignored, he escalated the issue by contacting the prison inspector’s office—only to be redirected back to Myers.
Lawsuit forces prison to turn over records
In June 2024, after months of being denied access, Adkins filed a lawsuit against prison officials, seeking a writ of mandamus to compel them to provide a copy of the handbook. He also sought damages for the delay.
Following the lawsuit, the prison finally gave him a copy of the handbook and the requested documents, leading the court to dismiss his case as moot. However, the justices still ruled on the prison’s failure to provide the records in a timely manner.
Court finds prison response improper
The Supreme Court rejected the prison’s defense, stating that Myers, as the public information officer, had a duty to properly respond to Adkins’ request and that directing him to unit staff was not an acceptable response.
The court also found that Myers’ initial denial of access was improper, particularly because Adkins had specifically requested both to inspect and obtain a copy of the handbook.
“Once Adkins requested a handbook, Myers had a duty to properly respond to the request, and advising Adkins to submit the request to another staff member was not a proper response,” the court wrote in its opinion.
Because of the unreasonable delay, the court ruled that Adkins was entitled to the maximum statutory damages of $1,000 under Ohio law. However, the court denied additional damages related to his requests for printed copies of his electronic kites, as it was unclear whether Myers was aware of those specific requests.