Ohio Case Commentaries

Strict Enforcement of Procedural Compliance Under Rule 17.09(A) and Timely Jurisdictional Filings

Date: May 28, 2025

Strict Enforcement of Procedural Compliance Under Rule 17.09(A) and Timely Jurisdictional Filings Introduction On May 27, 2025, the Supreme Court of Ohio issued its “Case Announcements”...

Elevating Ethical Accountability: Heightened Scrutiny of Elected Prosecutors under Prof.Cond.R. 8.4(h)

Date: May 23, 2025

Elevating Ethical Accountability: Heightened Scrutiny of Elected Prosecutors under Prof.Cond.R. 8.4(h) Introduction Disciplinary Counsel v. Black (Slip Opinion No. 2025-Ohio-1790) addresses the...

Mandatory Imprisonment for Underlying Felonies with Firearm Specifications under R.C. 2929.13(F)(8)

Date: May 22, 2025

Mandatory Imprisonment for Underlying Felonies with Firearm Specifications under R.C. 2929.13(F)(8) Introduction The Supreme Court of Ohio’s decision in State v. Logan, Slip Opinion No....

Discretionary Acceptance of Uncontested Facts and the Clear-and-Convincing Burden in Public-Records Mandamus: State ex rel. Ware v. Sheldon

Date: May 21, 2025

Discretionary Acceptance of Uncontested Facts and the Clear-and-Convincing Burden in Public-Records Mandamus: State ex rel. Ware v. Sheldon Introduction In State ex rel. Ware v. Sheldon, Slip Opinion...

Prof.Cond.R.1.6 Violations: Sanction for Unauthorized Disclosure to Law Enforcement

Date: May 9, 2025

Prof.Cond.R.1.6 Violations: Sanction for Unauthorized Disclosure to Law Enforcement Introduction Dayton Bar Association v. Daly, Slip Opinion No. 2025-Ohio-1624 (May 8, 2025), represents a...

Parole Authority Jurisdiction and the Proper Use of Extraordinary Writs: State ex rel. Ellis v. Adult Parole Authority

Date: May 9, 2025

Parole Authority Jurisdiction and the Proper Use of Extraordinary Writs Introduction State ex rel. Ellis v. Adult Parole Authority, Slip Opinion No. 2025-Ohio-1625, decided May 8, 2025, presented...

Clarifying Custodial Responsibility Under Ohio’s Public Records Act

Date: May 8, 2025

Clarifying Custodial Responsibility Under Ohio’s Public Records Act Introduction State ex rel. Clark v. Ohio Department of Rehabilitation and Correction, 2025-Ohio-1611, arose from a pro se mandamus...

Defining “Toxic Gases” in VSSR Claims Under Former Ohio Adm.Code 4123:1-5-01(B)(4)

Date: May 8, 2025

Defining “Toxic Gases” in VSSR Claims Under Former Ohio Adm.Code 4123:1-5-01(B)(4) Introduction This commentary analyzes the Ohio Supreme Court’s decision in State ex rel. Culver v. Industrial...

Clarifying Ohio’s Public Records Act Obligations: Proper Submission, Prepayment, and Custodial Duties in Prison Context

Date: May 7, 2025

Clarifying Ohio’s Public Records Act Obligations: Proper Submission, Prepayment, and Custodial Duties in Prison Context Introduction In State ex rel. Clark v. Ohio Department of Rehabilitation and...

Validity of Local Administrative‐Personnel Suspension Policies Under R.C. 3319.171

Date: May 2, 2025

Validity of Local Administrative‐Personnel Suspension Policies Under R.C. 3319.171 Introduction In State ex rel. Ruble et al. v. Switzerland of Ohio Local School District Board of Education...

Establishing the “Minimum Adverse Environmental Impact” and Public‐Need Standard for Ohio Solar Farms: In re Harvey Solar I, L.L.C. (2025-Ohio-1503)

Date: May 1, 2025

Establishing the “Minimum Adverse Environmental Impact” and Public-Need Standard for Ohio Solar Farms Introduction In In re Application of Harvey Solar I, L.L.C. (2025-Ohio-1503), the Supreme Court...

Establishing Uniform Procedural Deadlines for Delayed Appeals in the Ohio Supreme Court

Date: Apr 30, 2025

Establishing Uniform Procedural Deadlines for Delayed Appeals in the Ohio Supreme Court Introduction On April 29, 2025, the Supreme Court of Ohio issued its case announcements (2025-Ohio-1483),...

Defining “Reasonable Clarity” in Public Records Requests and the Mootness Doctrine under R.C. 149.43

Date: Apr 30, 2025

Defining “Reasonable Clarity” in Public Records Requests and the Mootness Doctrine under R.C. 149.43 Introduction This case arises from an original mandamus action brought by Estephen Castellon, a...

Judicial Finding Requirement for Incarcerated Requesters under R.C. 149.43(B)(8)

Date: Apr 18, 2025

Judicial Finding Requirement for Incarcerated Requesters under R.C. 149.43(B)(8) Introduction State ex rel. Mack v. Ohio State Highway Patrol Central Records (2025-Ohio-1332) arises from a pro se...

Establishing Mootness of Pretrial Bail Habeas Corpus Claims Upon Subsequent Conviction

Date: Apr 18, 2025

Establishing Mootness of Pretrial Bail Habeas Corpus Claims Upon Subsequent Conviction Introduction This commentary examines the Supreme Court of Ohio’s decision in Hayes v. Baldwin, Slip Opinion No....

Supreme Court of Ohio Reinforces Mandamus Procedures and Naming Requirements: Clarifying R.C. 2731.04 and Rules 12.04–12.05 (2025-Ohio-1313)

Date: Apr 17, 2025

Supreme Court of Ohio Reinforces Mandamus Procedures and Naming Requirements: Clarifying R.C. 2731.04 and Rules 12.04–12.05 (2025-Ohio-1313) Introduction On April 16, 2025, the Supreme Court of Ohio...

Appeal Availability Precludes Mandamus Relief: The Adequate Remedy Principle in State ex rel. Tentman v. Sundermann

Date: Apr 17, 2025

Appeal Availability Precludes Mandamus Relief: The Adequate Remedy Principle in State ex rel. Tentman v. Sundermann Introduction In State ex rel. Tentman v. Sundermann (2025-Ohio-1284), the Supreme...

Affirmation of Supreme Court of Ohio’s Summary Dismissal Authority and Discretionary Control Over Delayed Appeals

Date: Apr 16, 2025

Affirmation of Supreme Court of Ohio’s Summary Dismissal Authority and Discretionary Control Over Delayed Appeals Introduction On April 15, 2025, the Supreme Court of Ohio issued its case...

Common Pleas Courts Retain Declaratory-Judgment Jurisdiction Over Transferred Municipal Court Claims

Date: Apr 16, 2025

Common Pleas Courts Retain Declaratory-Judgment Jurisdiction Over Transferred Municipal Court Claims Introduction In State ex rel. Schwarzmer v. Mazzone (2025-Ohio-1246), the Supreme Court of Ohio...

Availability of Collective-Bargaining Grievance Procedures as an Adequate Remedy Bars Mandamus Relief

Date: Apr 11, 2025

Availability of Collective-Bargaining Grievance Procedures as an Adequate Remedy Bars Mandamus Relief Introduction In State ex rel. Johnston v. North Olmsted City School Dist. Bd. of Edn., Slip...