State ex rel. Striker v. Cline

Appellant Raleigh Striker filed a pro se complaint in the court of appeals for a writ of mandamus to compel Respondents, the clerk and the city of Shelby, to make certain records available for inspection and copying under the Ohio Public Records Act. The court of appeals denied Striker's request. Respondents subsequently filed a motion for sanctions against Striker, claiming that Striker had engaged in frivolous conduct in the public-relations mandamus case. The court of appeals awarded the clerk $3,503 in attorney fees as sanctions pursuant to Ohio Rev. Code 2323.51 for responding to Striker's frivolous assertions. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in awarding the clerk attorney fees for Striker's frivolous conduct because (1) the court properly determined that Striker had engaged in frivolous conduct that would authorize an award of reasonable attorney fees against him pursuant to section 2323.51, and (2) the reasonable fees incurred as a result of Striker's frivolous assertions were $3,503.