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State ex rel. Platt v. Montgomery Cty. Bd. of Elections

OhioFebruary 17, 2026No. 2024-0325
Plaintiff WinMontgomery Cty. Bd. of Elections$28,120 awarded
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Case Details

Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
Attorney fees application granted at reduced rate; respondents' good-faith exception defense rejected as untimely.

Related Laws

No specific laws identified for this ruling.

Outcome

Relator prevailed in attorney fees dispute. Court awarded $28,120 in attorney fees at $400/hour, rejecting respondents' $690/hour rate and their late invocation of the good-faith exception under former R.C. 149.43(C)(3)(c).

Excerpt

Attorney fees—$400 an hour determined to be reasonable rate given respondents' concession and the absence of satisfactory evidence submitted by relator in support of $690 rate billed by relator's attorneys—Respondents invoked "good-faith exception" too late because former R.C. 149.43(C)(3)(c) does not provide a basis for reducing an award of attorney fees but, rather, applies only to the court's initial determination of whether to award fees to a prevailing relator—Relator's attorney-fee application granted in amount of $28,120.

What This Ruling Means

**What Happened** Platt requested public records from the Montgomery County Board of Elections, but the agency failed to properly provide them. This led to a legal dispute where Platt sued to get the records and sought to recover attorney fees for having to take the matter to court. **What the Court Decided** The court ruled in Platt's favor and ordered the Board of Elections to pay $28,120 in attorney fees. The court set the reasonable hourly rate at $400 per hour for Platt's attorneys, rejecting their request for $690 per hour. The Board tried to use a "good-faith exception" to reduce the fee award, but the court said they waited too long to raise this defense and it didn't apply to reducing fees anyway. **Why This Matters for Workers** This case shows that government agencies must follow public records laws, and when they don't, they may have to pay the legal costs of people who successfully sue them. For workers dealing with government employers or seeking workplace-related public records, this demonstrates that courts will enforce these transparency laws and make agencies pay attorney fees when they wrongfully withhold information.

This summary was generated to explain the ruling in plain English and is not legal advice.

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