The Second Appellate District of Ohio has affirmed a lower court’s decision to deny a public records request made by Diahntae Bell, who is serving a life sentence for a 2007 murder. The court found that Bell failed to demonstrate a “justiciable claim” that would justify the release of the requested records.
Background of the Case
{¶ 2} The case stems from a 2007 incident in which Bell was convicted of felony murder. The events leading to the conviction began when Bell was seen exiting an apartment that was being rented by an incarcerated individual. He was confronted by residents of a neighboring apartment. After an altercation that involved a gun, Bell shot and killed L.B. Bell was arrested and subsequently indicted on multiple charges. A jury found him guilty of four counts, including felony murder, and he was sentenced to 23 years to life in prison.
{¶ 7} Bell has filed multiple appeals and motions over the years, all of which have been unsuccessful. These included a direct appeal, motions for resentencing, petitions to vacate his conviction, and several applications for DNA testing of various pieces of evidence. The court has consistently denied these requests.
The Public Records Request
{¶ 12} In March 2025, Bell filed a motion requesting public records related to his case. He sought access to documents concerning the potential loss or destruction of evidence, dispatch records from Detective Jay A. Vitali, 911 tapes related to the offense, and a copy of the prosecutor’s investigative file.
{¶ 15} Under Ohio law (R.C. 149.43(B)(8)), incarcerated individuals seeking public records related to a criminal investigation or prosecution face additional hurdles. The law requires them to demonstrate that the information they are seeking is necessary to support a “justiciable claim.” A “justiciable claim” is one that can properly be brought before a court for relief.
The Court’s Reasoning
{¶ 19} The court found that Bell’s public records request was essentially an attempt to indirectly obtain information that would support his requests for DNA testing. The court noted that Bell’s previous applications for DNA testing had been denied. The court concluded that Bell had not demonstrated a justiciable claim necessary to support the public records request. The court stated that Bell’s motion was a “backdoor attempt” to obtain the DNA testing that he had previously been denied.
The Ruling
{¶ 21} The Second Appellate District affirmed the trial court’s decision, upholding the denial of Bell’s public records request. The court found that the trial court had not abused its discretion in its ruling.