Ohio Supreme Court Sides with Geauga Sheriff in Records Case

April 3, 2026 by Staff Report

The Ohio Supreme Court on Thursday ruled in favor of the Geauga County Sheriff’s Office in a public records dispute, finding the office did not violate state law when it declined to provide records the requester failed to prove existed during the time period sought.

In a unanimous per curiam decision, the court denied a writ of mandamus sought by Jocelyn Rosnick of the ACLU of Ohio Foundation, who had requested records related to possible agreements between the sheriff’s office and several federal agencies, including U.S. Immigration and Customs Enforcement.

Rosnick submitted the request March 12, 2025, seeking contracts, draft contracts and related memorandums between the sheriff’s office and the U.S. Department of Homeland Security, ICE and the U.S. Marshals Service from June 1, 2024, through March 3, 2025.

The sheriff’s office later provided records responsive to two portions of the request but denied the section involving federal contracts. In its initial response, the office stated that “the release of such records is prohibited by federal law” and said Geauga County “contracts with the federal government for the housing of ICE detainees.”

During the litigation, however, the sheriff’s office submitted an affidavit from its records clerk stating the office had not executed any contracts with DHS, ICE or the U.S. Marshals Service during the time period specified in Rosnick’s request. The affidavit did acknowledge the sheriff’s office executed a contract with the U.S. Marshals Service on March 20, 2024, which took effect April 1, 2024, but the court said that agreement fell outside the date range requested.

In rejecting Rosnick’s claim, the justices wrote that she “has not established by clear and convincing evidence that the sheriff’s office possesses records responsive to her public-records request that it has failed to produce.”

The court further concluded that because Rosnick had not shown the office possessed additional responsive records, she was not entitled to the extraordinary relief she sought.

“As Rosnick has not established by clear and convincing evidence that the sheriff’s office possesses records responsive to her request and that it has failed to produce those records, she has not shown that she is entitled to the requested writ of mandamus,” the opinion stated.

The justices also rejected Rosnick’s argument that the sheriff’s office should have said earlier that it did not possess the requested records. The opinion noted that Ohio’s Public Records Act “does not prohibit a public office from asserting for the first time in litigation that it does not possess records responsive to a public-records request.”

Rosnick had also asked the court for statutory damages, attorney fees and court costs, but those requests were denied. The court additionally rejected her motion to submit revised evidence, finding it was filed too late under the court’s rules.

The case is State ex rel. Rosnick v. Geauga County Sheriff’s Office, Slip Opinion No. 2026-Ohio-1127, decided April 2.