LAW.coLAW.co

State v. Muskingum

2026-08-25

Summary

Holding. The court affirmed that the requested records are confidential under state law and not public records subject to disclosure, and that neither the Agency nor the assistant prosecuting attorney had a clear legal duty to provide them. The case is dismissed.

Randall Conway filed a public records request with Muskingum County's Adult and Child Protective Services Agency seeking documents about a foster child placed in his home, including records of the child's psychological, behavioral, medical, and developmental history. When the Agency did not produce the records, Conway filed a mandamus action against both the Agency and Mark Zanghi, an assistant prosecuting attorney who provides legal counsel to the Agency, seeking to compel disclosure of the documents.

The appellate court determined that the requested records are confidential under Ohio law and therefore not subject to disclosure as public records. The court also found that Zanghi, as legal counsel rather than a record keeper, bore no obligation to provide the Agency's records. Because the Agency had no clear legal duty to release confidential children's services records and Zanghi had no duty to produce records at all, the court granted summary judgment in favor of both respondents. The court also denied Conway's request for statutory damages and court costs.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether confidential children's services records are public records under Ohio's Public Records Act
  • Whether an agency's legal counsel has an obligation to produce public records
  • Whether good cause exists to override statutory confidentiality requirements for foster care records
  • Whether statutory damages are warranted when no underlying duty to disclose exists

Procedural posture

The respondents' motions to dismiss were converted to summary judgment motions after the court received affidavits from all parties, and the court granted judgment in favor of both respondents on summary judgment.

Authorities cited

Opinion

majority opinion

[Cite as State v Muskingum, 2026-Ohio-3320.]

IN THE OHIO COURT OF APPEALS

FIFTH APPELLATE DISTRICT

MUSKINGUM COUNTY, OHIO

STATE EX REL. RANDALL W. Case No. CT2026-0057

CONWAY,

Opinion & Judgment Entry

Relator

Judgment: Case Dismissed

-vsDate of Judgment: August 25, 2026

MUSKINGUM COUNTY ADULT

AND CHILD PROTECTIVE

SERVICES, et al.,

Respondents

BEFORE: Andrew J. King, Robert G. Montgomery, and David M. Gormley, Judges

APPEARANCES: Randall W. Conway, Cass City, Michigan, briefed the case on his own behalf as Relator; Ronald L. Welch (Muskingum County Prosecuting Attorney) and Mark A. Zanghi (Assistant Prosecuting Attorney), Zanesville, Ohio, for Respondents.

Gormley, J.

{¶1} In this mandamus case, relator Randall Conway asks us to compel the Adult

and Child Protective Services agency in Muskingum County (“the Agency”) to provide to

him some documents that address the Agency’s placement of a foster child in the Conway

home. Conway has named as an additional respondent in the case an assistant prosecuting

attorney in Muskingum County who provides legal representation to the Agency. Because

we conclude that the two respondents are under no clear legal duty to provide the requested

documents to Conway, we dismiss his complaint.

The Key Facts

{¶2} Conway sent a written public-records request to the Agency in July 2025, and

in it he asked for various records concerning a particular foster child, including documents addressing the child’s psychological, behavioral, medical, or developmental history. The

assistant prosecuting attorney who has been named as a respondent in this case — Mark

Zanghi — sent a prompt acknowledgment to Conway indicating that his request had been

received, but the Agency never provided any documents to Conway.

{¶3} In the mandamus complaint that Conway filed here in June 2026, he alleges

that the Agency and Zanghi are obligated under Ohio’s Public Records Act — R.C. 149.43

— to provide him copies of the documents he seeks. After the Agency and Zanghi filed

motions asking us to dismiss Conway’s complaint, Conway filed a motion seeking summary

judgment in his favor. Because we received affidavits from all three parties in the case, we

notified the parties that we would treat the respondents’ motions to dismiss as summaryjudgment motions, and we gave the parties additional time to respond to each other’s filings.

All briefing on the various motions is now concluded.

The Key Legal Standards

{¶4} Under R.C. 149.43(B)(1), any “public records” must be made available for

inspection and copying within a reasonable period of time. That statutory provision “is

construed liberally in favor of broad access,” and any doubt is resolved in favor of the

disclosure of public records. State ex rel. Cincinnati Enquirer v. Hamilton Cty., 75 Ohio St.3d

374, 376 (1996), citing State ex rel. Thomas v. Ohio State Univ., 71 Ohio St.3d 245, 246 (1994).

{¶5} According to R.C. 149.43(C)(1)(b), a mandamus action is the remedy for a

person who alleges that he or she has been denied access to a public record. To prevail on a

claim for mandamus relief in a public-records case, a party must establish a “clear legal right

to the requested relief” as well as a “corresponding clear legal duty on the part of the

respondents” to provide that relief. State ex rel. Penland v. Ohio Dept. of Rehab. and Correction, 2019-Ohio-4130, ¶ 9, citing State ex rel. Am. Civ. Liberties Union of Ohio, Inc. v. Cuyahoga Cty. Bd.

of Commrs., 2011-Ohio-625, ¶ 22.

{¶6} And because this case is now before us on dueling summary-judgment motions,

we apply the usual Civil Rule 56 standard, granting judgment only if it appears from the

pleadings and other evidence in the case that: (1) there is no genuine issue as to any material

fact; (2) the moving party is entitled to judgment as a matter of law; and (3) reasonable minds

can come to but one conclusion, with that conclusion being adverse to the party against whom

the motion for summary judgment is made. McCord v. Ron Laymon Trucking Co., 2005-Ohio

4399, ¶ 22 (5th Dist.); Civ.R. 56(C).

Zanghi Himself is Not Obligated to Provide the Requested Records

{¶7} According to R.C. 149.43(B)(1), any public-records request is properly directed

only to a “public office or person responsible” for the requested records. And a “person

responsible” for public records is one obligated by law to oversee them. State ex rel. Cincinnati

Post v. Schweikert, 38 Ohio St.3d 170, 174 (1988), citing R.C. 149.43(B). See also State ex rel.

MADD v. Gosser, 20 Ohio St.3d 30, paragraph two of the syllabus (1985) (when “statutes

impose a duty on a particular official to oversee records, that official is the ‘person

responsible’” for the records under R.C. 149.43(B)).

{¶8} All evidence filed in the case indicates that though Zanghi provides legal

services and legal representation to the Agency, he is not the person tasked with providing

any of the Agency’s public records to others. He does not oversee or maintain those records

himself, he is not an Agency employee, and no statutory provision imposes on him a duty to

keep or to provide copies of the records.

{¶9} Given Zanghi’s role as the Agency’s counsel rather than its record keeper, we

readily conclude that he has no obligation to provide to Conway any of the Agency’s records.

See State ex rel. Keating v. Skeldon, 2009-Ohio-2052, ¶ 17 (6th Dist.) (granting summary

judgment in favor of an assistant prosecuting attorney in a public-records mandamus action

that was brought against that attorney and the Lucas County dog warden to obtain records

from the dog warden’s office).

{¶10} Zanghi’s summary-judgment motion is granted, and Conway’s cross-motion

seeking summary judgment against Zanghi is denied.

The Requested Records Are Confidential and So Are Not Public Records

{¶11} Conway’s mandamus complaint — like his earlier public-records request —

asks the Agency to provide to him certain records concerning a child’s psychological,

behavioral, medical, and developmental history, along with documents addressing any of the

child’s diagnoses, educational assessments, or behavioral interventions. Conway also seeks

the Agency’s internal records or correspondence showing whether a formal disclosure packet

was created and distributed for the child’s adoptive placement, as well as any forms signed by

Conway and his wife acknowledging receipt of those disclosures.

{¶12} Under R.C. 5153.17(A), a public children’s services agency is tasked with

keeping written records of the following: “(1) [i]nvestigations of families, children, and foster

homes; (2) [t]he care, training, and treatment afforded to children; (3) [s]uch other records as

are required by the department of children and youth.” Those kinds of records are, according

to R.C. 5153.17(B), to remain “confidential,” aside from inspections of them by “[t]he agency,

the director of children and youth, and the director of the county department of job and family

services, and by other persons upon the written permission of the executive director.”

{¶13} Excluded from the definition of “public record” in Ohio is any record “the

release of which is prohibited by state or federal law.” R.C. 149.43(A)(1)(v).

{¶14} The Supreme Court has repeatedly turned aside public-records requests for the

kind of confidential records that are at issue in this case. See, e.g., State ex rel. Martin v.

Tuscarawas Cty. Job & Family Servs., 2020-Ohio-3507, ¶ 26 (explaining that an “unsubstantiated

allegation” that access to certain children’s-services records would “improve the[ ] emotional

well-being” of the requesting parties was not sufficient to overcome the statute’s

confidentiality requirement, “let alone sufficient to show” that the agency in question “had a

clear legal duty” to release the records); State ex rel. Clough v. Franklin Cty. Children Servs., 2015-Ohio-3425, ¶ 26 (explaining that while “good cause” might justify the granting of a request

for confidential children’s-services records, no good cause existed where the child in question

faced no specific danger, no due-process rights were in jeopardy, and no compelling reason

for departing from the statute’s confidentiality requirement had been offered); State ex rel.

Renfro v. Cuyahoga Cty. Dept. of Human Servs., 54 Ohio St.3d 25, 29 (1990) (denying a records

request and explaining that “keeping foster care records confidential . . . is [the agency’s]

primary responsibility under the statute”).

{¶15} And just last year, the Ohio Court of Claims likewise rejected a records request

directed to a county children’s-services agency by a former foster child who sought records

from her own case file. See Daniel v. Cuyahoga Cty. Div. of Children & Family Servs., 2025-Ohio5266, ¶ 27 (Ct. of Cl.) (describing the records as confidential and not public records).

{¶16} We reach the same result here. The records sought by Conway focus on the

Agency’s investigation of Conway’s family and the care and treatment that the child received from the Agency and others. Any records documenting that information fall within the scope

of R.C. 5153.17(B)’s confidentiality provision.

{¶17} The executive director of the Agency has filed an affidavit in the case, and she

indicates in that affidavit that the children’s-services records sought by Conway are

“confidential” and therefore not subject to public release. In response, Conway has offered

no evidence that might support any good-cause argument for the Agency or this court to allow

him to inspect or receive copies of the confidential records he seeks.

{¶18} Because the records in question are designated as confidential by R.C.

5153.17(B), they are not public records under Ohio’s Public Records Act. See State ex rel.

Miami Student v. Miami Univ., 79 Ohio St.3d 168, 170 (1997) (noting that R.C. 149.43

“provides for full access to all public records upon request unless the requested records fall

within one of the specific exceptions listed in the Act” and one such exception is records “the

release of which is prohibited by state or federal law”) (quotations omitted).

{¶19} The Agency has no clear legal duty to release the records, and we therefore

grant the Agency’s summary-judgment motion. Conway’s cross-motion seeking summary

judgment against the Agency is denied.

Conway Is Not Entitled to Statutory Damages or Court Costs

{¶20} Conway also contends that he is entitled to statutory damages and court costs

because the Agency failed to promptly produce the requested information. Statutory damages

can be awarded in a public-records mandamus action if the court determines that the public

office failed to comply with an obligation under R.C. 149.43(B). See R.C. 149.43(C)(3); State

ex rel. Castellon v. Cuyahoga Cty. Prosecutor’s Office, 2025-Ohio-2787, ¶ 18 (noting that the publicrecords requester bears the burden to prove “by clear and convincing evidence” that he or she

is entitled to statutory damages).

{¶21} Nothing in the record before us demonstrates that the Agency has any

obligation under R.C. 149.43(B) to provide the requested confidential records to Conway, so

we deny his request under R.C. 149.43(C)(3) for statutory damages. We likewise deny his

request for court costs under R.C. 149.43(C)(4)(a)(i). See State ex rel. Rosnick v. Geauga Cty.

Sheriff’s Office, 2026-Ohio-1127, ¶ 22 (denying a request for statutory damages, attorney fees,

and court costs in a mandamus action when the public office did not breach any obligation

under the Public Records Act).

{¶22} In sum, we grant the summary-judgment motions filed by Zanghi and the

Agency, and we deny Conway’s similar motions seeking judgment in his favor. Today’s

judgment in the respondents’ favor means that the case is dismissed.

{¶23} Any costs must be paid by relator Conway. The clerk of courts should serve a

copy of this judgment on all parties in accordance with Civil Rule 58(B).

By: Gormley, J.;

King, P.J. and

Montgomery, J. concur.