Political subdivisions need only be reasonable, not Herculean, in their attempts to locate records to be produced in response to public records request.

A relator filed a mandamus action to compel the City of Sheffield to produce documents in response to a public records request. Despite utilizing an outside IT vendor, the City was unable to locate any images of the documents on a desktop computer where the images allegedly originated. The relator argued that the City wrongly only searched one computer and did not search all electronic devices, including printers, where the images may have been located. The Ohio Supreme Court said the City’s search was enough and only needed to be reasonable. In dismissing the relator’s argument that the City had to keep searching other electronic devices in its possession, the Ohio Supreme Court said that the relator’s suggestion that the City must search every computer that could possibly harbor the missing images had “no stopping point” and was not required under Ohio law.

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