McEachron v. Brecksville

[Cite as McEachron v. Brecksville, 2026-Ohio-1323.]

IN THE COURT OF CLAIMS OF OHIO

ORVILLE MCEACHRON Case No. 2026-00056PQ

Requester Special Master Sarah Pierce

v. REPORT AND RECOMMENDATION

CITY OF BRECKSVILLE

Respondent

{¶1} This matter is before me for a report and recommendation. R.C.2743.75(F). I

recommend that the Court (1) enter judgment for respondent, and (2) order requester to

bear the costs of this case.

I. Background

{¶2} In November 2024, Requester Orville McEachron was cited for a traffic

violation. Complaint, filed Jan. 16, 2026, p. 13-14. The case was docketed in the

Brecksville Mayor’s Court under case number 24TRD00912. Id. On January 8, 2025, the

case was transferred to the Garfield Heights Municipal Court and docketed in case

number TRD250061. Compl., p. 11-12; see also Brecksville v. McEachron, Garfield

Heights Mun. Ct. No. TRD2500061, Docket (attached at Appendix A).1

{¶3} Requester contests the response to two public records requests he made to

Respondent the City of Brecksville. Compl., p. 1. These requests generally relate to the

1 I take judicial notice of the docket in the Garfield Heights traffic case and the filings

available on that docket. Courts can take judicial notice of filings readily accessible from

a court’s website. Gold v. Bertram, 2023-Ohio-4567, ¶ 18 (4th Dist.); see also Evid.R.

201. The Garfield Heights traffic case docket is available at:

https://docket.ghmc.org/recordSearch.php?k=docket1828Z7Qzc8szh8fnUwBUIsutOZn

Q92Vpmbxv7ssoVA9M201947156251794433789423830997111280944820185680168

35371122009546043576648529426 (last accessed Mar. 9, 2026). The docket is also

attached to this report and recommendation at Appendix A, for the reader’s convenience.

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Brecksville Mayor’s Court traffic case and its transfer to the Garfield Heights Municipal

Court. See Compl., p. 2-3, 58-61.

A. The January 2025 public records request (First Request)

{¶4} The first request was made on January 14, 2025, and submitted by fax to the

Brecksville Mayor’s Court Clerk. Compl., p.1, 34-35. The request was titled a “Request

for Complete Case File and Confirmation of Records Transferred to Garfield Heights

Municipal Court.” Compl., p. 35, 37. It asked for,

1. A copy of the complete case file associated with my case [Brecksville

Mayor’s Court case no. 24TRD00912], including but not limited to all

records, filings, and docket entries held by Brecksville Mayor’s Court,. 2.

Confirmation of what records were transferred to Garfield Heights Municipal

Court as part of the case transfer. This request specifically includes but not

limited to all motions and filings, such as the Emergency Combined Motion

to Object to Transfer and to Clarify and Correct the Record, filed on January

8, 2025, as well as any other documents relevant to this matter.

Compl., p. 35-36 (emphasis omitted).

{¶5} In the request letter, Requester notes that he “spoke with a Deputy Clerk from

the Garfield Heights Clerk of Courts as part of a follow-up regarding access/copies to my

case records.” Compl., p. 36. That conversation led to “additional concerns about the

completeness of the case transfer and the availability of important case materials for my

preparation.” Id. Requester therefore made the request to “ensure access to all relevant

records and to preserve procedural fairness.” Id., p. 37. He also provided a copy of the

request to the “Garfield Heights Clerk of Courts to ensure it is added to the record in

Garfield Heights Municipal Court and to document my efforts to address the

completeness of the case file.” Id. He asked for “a prompt response, as access to these

records is critical for preparing for my upcoming hearing on January 15, 2025.” Id.

Requester was heard on these issues by a magistrate in the Garfield Heights Municipal

Court. Brecksville v. McEachron, Garfield Heights Mun. Ct. No. TRD2500061, Decision

(Jan. 24, 2025).2

2 A copy of this decision is attached to this report and recommendation at Appendix B.

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{¶6} Requester alleges that he has received no response or records from the City

on this request. Compl., p. 1.

B. The December 2025 public records request (Second Request)

{¶7} The second request was made on December 23, 2025 by email. Compl., p.

1, 8. The request asked for “electronic copies of the following public records from City of

Brecksville / Brecksville Mayor’s Court in Case No. 24TRD00912” and listed 20 separate

items. Compl., p. 8-9. Requester alleges that he has received no records in response to

that request. Compl., p. 1.

{¶8} The City responded to the second request on December 29, 2025. Compl., p.

7. The City notified Requester that any responsive records had already been provided to

him, stating

All records held by the Brecksville Mayor’s Court were transferred to the

Garfield Heights Municipal Court on January 8, 2025 and were docketed on

the Garfield Heights Municipal Court website. Further, the City of Brecksville

timely filed its Discovery Response and State’s Motion for Discovery dated

January 20, 2025, which was uploaded to the Garfield Heights Municipal

Court Case Center portal in which you were given access to review.

Redundant requests for records pertaining and resulting from the charge of

Failure to Control on or about November 10, 2024 are unnecessary as you

have been provided all records via discovery as well as your public access

to the Garfield Heights Municipal Court docket.

Compl., p. 9.

C. Procedural history

{¶9} On Requester’s motion, mediation was bypassed in this case. A schedule was

set for both parties to file evidence and memoranda supporting their positions. That

schedule has run its course, making this case ripe for decision. Order Bypassing

Mediation, entered Jan. 23, 2026.

II. Analysis

A. Requester is not entitled to relief on his first request.

{¶10} Requester alleges that he has not received a response or records from the

City on his first request. Compl., p. 1. In the preliminary complaint sent to the City,

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Requester made the same allegation and stated that the request had been pending for

over 11 months. Compl., p. 25-28.

{¶11} Production claim. The City argues that the first request was handled as a

request for discovery under Criminal Rule 16. Resp. Brief, filed Feb. 18, 2026, p. 2. In the

context of a criminal proceeding, a “public records request is the equivalent of a demand

for discovery.” State ex rel. Caster v. City of Columbus, 2016-Ohio-8394, ¶ 38.

{¶12} Given the context, the City’s treatment of the first request as a discovery

demand was a reasonable response. Requester submitted the request on January 14,

2025. Compl., p. 34. Requester had an ongoing criminal case before the Garfield Heights

Municipal Court. See Appendix A. Requester referenced that case in his request and

predicated his need for records on the needs of that case. Compl., p. 36-37. Requester

was provided access to that discovery via a digital evidence portal on January 21, 2025.

See Appendix A. That docket entry is consistent with the discovery response and other

email correspondence filed by the City in this public records case. Resp. Ev., p. 3-5; Resp.

Br., p. 10.

{¶13} The City filed its discovery response in the Garfield Heights traffic case with

this court. See Resp. Evidence, filed Feb. 4, 2026, p. 3-92. The discovery response

included the original traffic investigation, the transfer entry, internal case notes from the

Brecksville Mayor’s Court, case entries from the Garfield Heights Municipal Court, and

Requester’s correspondence to both courts. Resp. Ev., p. 3-92. This response

encompasses the material required by Criminal Rule 16(B). See Resp. Ev., p. 1-2; 4-29.

It also includes material responsive to the first request for “[a] copy of the complete case

file associated with my case.” Compl., p. 35; Resp. Ev., p. 32-92 (internal case notes,

case entries, and correspondence). From my review of the documents provided to

Requester, I conclude that this criminal discovery production includes records responsive

to his first request and confirms that the City treated the first request as a criminal

discovery demand.

{¶14} Requester is correct that he is not obligated to follow up with the City about

a public records request. Req. Reply, filed Mar. 2, 2026, p. 4. Having answered the

discovery request, however, the City had no further obligation under the Public Records

Act to respond to the first request. I also note that the City had no indication that the

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request was not satisfied from Requester’s perspective. Some cooperation is envisioned

by the Public Records Act. State ex rel. Morgan v. Strickland, 2009-Ohio-1901, ¶ 18; see

also State ex rel. Fluty v. Raiff, 2023-Ohio-3285, ¶ 24.

{¶15} Delay claim. Requester argues that his first request has been pending,

unanswered, since January 14, 2025. Compl., p. 25-28. I disagree. As noted above, I find

that the City reasonably treated the request as a criminal discovery demand. That demand

was answered on January 21, 2025. See Appendix A. The City was not obligated by the

Public Records Act to provide a further response to requester.

{¶16} Summary. I recommend that the court find that Requester is not entitled to

relief on his first request. The City reasonably treated the request as a criminal discovery

demand and answered it accordingly. The City had no further obligation under the Public

Records Act to respond to the request.

B. Second request

{¶17} Requester alleges that he has not received records from the City in response

to his second request. Compl., p. 1. The second request listed 20 separate items. Compl.,

p. 8-9. Each request asked for a particular type of document from the Brecksville Mayor’s

Court traffic case “dated on or before January 7, 2025.” Id.

{¶18} Requester received a response to this request. On December 29, 2025, the

City informed Requester that “[a]ll records held by the Brecksville Mayor’s Court were

transferred to the Garfield Heights Municipal Court” and docketed on that court’s public

website. Compl., p. 9. The City also reminded Requester that he received the City’s

discovery response in that case on January 20, 2025. Id. The City concluded by stating

that “you have been provided all records via discovery as well as your public access to

the Garfield Heights Municipal Court docket.” Id.

{¶19} Production. In general, a public office is not obligated to respond to

duplicative public records requests. State ex rel. Adkins v. Dept. of Rehab. & Correction

Legal Dept., 2024-Ohio-5154, ¶ 15; see also State ex rel. Brown v. Village of N.

Lewisburg, 2013-Ohio-3841, ¶ 19-20 (2nd Dist.); State ex rel. Laborers Internatl. Union

of N. Am., Local Union No. 500 v. Summerville, 2009-Ohio-4090, ¶ 6. The City responded

to the second request to state that Requester had already received any responsive

records. Compl., p. 9. While the second request did not use phrasing identical to the first

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request, the second request sought case documents associated with the Brecksville

Mayor’s Court traffic case. The City informed Requester that these records had already

been provided to him.

{¶20} Requester argues that he is entitled to a further response on his second

request. First, Requester argues that he has not received a complete set of responsive

records. Req. Reply, p. 7-8, 9-10. The City has responded that it has already provided all

responsive records to him. Requester does not provide any evidence that further

responsive records exist. See Sell v. Trumbull Cty. Juv. Div., 2024-Ohio-6139, ¶ 6 (Ct. of

Cl.) (noting “some evidence” of the existence of records may be sufficient). Second,

Requester argues that the City was required to respond individually to each of his 20

requests. Req. Reply, p. 7. I do not find support for this argument. The response to each

of the requests was, essentially, responsive records have already been provided.

{¶21} I recognize that the initial production of responsive records was made as a

discovery production under Criminal Rule 16. Even if the City was required to reissue

these records in response to the second request, those records have been provided

during this litigation. State ex rel. Striker v. Smith, 2011-Ohio-2878, ¶¶ 17-18, 22 (public-

records claim mooted when records provided during litigation); Kearns v. Boardman Twp.

Police Dept., 2025-Ohio-475, ¶ 7 (same), adopted at Ct. of Cl. No. 2024-00776PQ (Mar.

19, 2025). There is no further relief that this court can order. I therefore recommend that

the court find that Requester is not entitled to any further production of records in

response to his second request.

{¶22} Delay. Requester did not raise a delay claim in his complaint. Hastings v.

Washington Court House Bldg./Zoning Dept., 2025-Ohio-1292, ¶ 7 (Ct. of Cl.) (“[T]he the

only matters properly before the Court or Special Master are those identified in the body

of the complaint.”).

C. Costs.

{¶23} Revised Code 2743.75(F)(3)(b) provides that the court shall award a

requester their filing fee and “any other costs associated with the action” if it finds a

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violation of the Public Records Act. Because I do not find a violation, I recommend that

the court order the balance of costs assessed against Requester.

III. Conclusion

{¶24} Based on the above considerations, I recommend that the court:

1) Enter judgment for respondent; and

2) Order requester to bear the costs of this case.

{¶25} Pursuant to R.C. 2743.75(F)(2), either party may file a written objection with

the clerk of the Court of Claims of Ohio within seven (7) business days after receiving this

report and recommendation. Any objection shall be specific and state with particularity

all grounds for the objection. A party shall not assign as error on appeal the court’s

adoption of any factual findings or legal conclusions in this report and recommendation

unless a timely objection was filed thereto. R.C. 2743.75(G)(1).

SARAH PIERCE

Special Master

Filed March 10, 2026

Sent to S.C. Reporter 4/13/26

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APPENDIX A

Case No. 2026-00056PQ -9- REPORT AND RECOMMENDATION

Case No. 2026-00056PQ -10- REPORT AND RECOMMENDATION

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APPENDIX B