Ohio Case Commentaries

Mandamus Limits in Election Cases: Referrals for Investigation Are Injunctive Relief; Voting/Candidate Residency Requires Intent Tethered to a Fixed Habitation

Date: May 5, 2026

Mandamus Limits in Election Cases: Referrals for Investigation Are Injunctive Relief; Voting/Candidate Residency Requires Intent Tethered to a Fixed Habitation I. Introduction In State ex rel....

Physical Holding and Continued Sexual Conduct After Refusal May Establish Force in Juvenile Rape Adjudications

Date: May 4, 2026

Physical Holding and Continued Sexual Conduct After Refusal May Establish Force in Juvenile Rape Adjudications Introduction In In re P.M.S., 2026-Ohio-1543, the Supreme Court of Ohio addressed what...

PUCO Prudency Reviews: Must-Run Strategy Judged Without Hindsight; Subpoenas Discretionary; Auditor Independence Requires “Undue Influence,” Not Mere Appearance

Date: Apr 29, 2026

PUCO Prudency Reviews: Must-Run Strategy Judged Without Hindsight; Subpoenas Discretionary; Auditor Independence Requires “Undue Influence,” Not Mere Appearance I. Introduction Case: In re Rev. of...

2026-Ohio-1471: Summary Dispositions and Procedural Orders—No New Substantive Precedent, but Clear Signals on Mootness and Gatekeeping

Date: Apr 29, 2026

2026-Ohio-1471: Summary Dispositions and Procedural Orders—No New Substantive Precedent, but Clear Signals on Mootness and Gatekeeping Court: Supreme Court of Ohio Date: April 28, 2026 Citation:...

Penn Central “Investment-Backed Expectations” Must Track Known Regulatory Risk—Agency “Stonewalling” Does Not Create a Taking

Date: Apr 29, 2026

Penn Central “Investment-Backed Expectations” Must Track Known Regulatory Risk—Agency “Stonewalling” Does Not Create a Taking Case: State ex rel. AWMS Water Solutions, L.L.C. v. Mertz, Slip Opinion...

In re L.E.S. (2026-Ohio-1449): R.C. 3111.95(A) Cannot Be Retroactively Extended to Unmarried Same-Sex Partners via a “Would Have Been Married” Test

Date: Apr 29, 2026

In re L.E.S. (2026-Ohio-1449): R.C. 3111.95(A) Cannot Be Retroactively Extended to Unmarried Same-Sex Partners via a “Would Have Been Married” Test 1. Introduction In re L.E.S., E.S., and N.S. is an...

Ordinary Lawn Maintenance Is Not “Open and Notorious” Enough to Start Ohio’s 21-Year Adverse-Possession Clock

Date: Apr 27, 2026

Ordinary Lawn Maintenance Is Not “Open and Notorious” Enough to Start Ohio’s 21-Year Adverse-Possession Clock 1. Introduction In NC Ents., L.L.C. v. Norfolk & W. Ry. Co., Slip Opinion No....

Fair-Notice and Context Rule for Public-Records Requests Embedded in Administrative Grievances (Ohio)

Date: Apr 24, 2026

Fair-Notice and Context Rule for Public-Records Requests Embedded in Administrative Grievances (Ohio) Introduction In State ex rel. Howard v. Chief Inspector's Office, Slip Opinion No....

R.C. 2953.21 Is the Exclusive Vehicle for Collateral Attacks: Civ.R. 60(B) Cannot Reopen Postconviction Judgments

Date: Apr 24, 2026

R.C. 2953.21 Is the Exclusive Vehicle for Collateral Attacks: Civ.R. 60(B) Cannot Reopen Postconviction Judgments I. Introduction State v. Hill, Slip Opinion No. 2026-Ohio-1427 (Supreme Court of...

State v. J.B. (2026-Ohio-1405): Trial Courts May Weigh Number/Nature of Convictions and Governmental Interests Sua Sponte When Deciding Sealing Under R.C. 2953.32

Date: Apr 24, 2026

State v. J.B. (2026-Ohio-1405): Trial Courts May Weigh Number/Nature of Convictions and Governmental Interests Sua Sponte When Deciding Sealing Under R.C. 2953.32 1. Introduction In State v. J.B.,...

Third-Party Electric Submetering Providers Are “Electric Light Companies” (Public Utilities) Under R.C. 4905.03(C)

Date: Apr 24, 2026

Third-Party Electric Submetering Providers Are “Electric Light Companies” (Public Utilities) Under R.C. 4905.03(C) 1. Introduction Case: In re Complaint of Ohio Power Co. v. Nationwide Energy...

Strict-Compliance Rule: Inmate Affidavits Must List Every Party in Every Prior Civil Action Under R.C. 2969.25(A)(3)

Date: Apr 16, 2026

Strict-Compliance Rule: Inmate Affidavits Must List Every Party in Every Prior Civil Action Under R.C. 2969.25(A)(3) 1. Introduction State ex rel. Bates v. Copley, 2026-Ohio-1270 is a Supreme Court...

Electronically Soliciting a Client’s Significant Other for Sex as Prof.Cond.R. 8.4(h) Misconduct; Actual Two-Year Suspension for Combined Neglect, Dishonesty, and Noncooperation

Date: Apr 16, 2026

Electronically Soliciting a Client’s Significant Other for Sex as Prof.Cond.R. 8.4(h) Misconduct; Actual Two-Year Suspension for Combined Neglect, Dishonesty, and Noncooperation I. Introduction In...

Mandatory R.C. 3503.24(B) Hearing When Records Are Insufficient; Statewide Elector Standing and Limited Res Judicata in Voter-Registration Challenges

Date: Apr 16, 2026

Mandatory R.C. 3503.24(B) Hearing When Records Are Insufficient; Statewide Elector Standing and Limited Res Judicata in Voter-Registration Challenges 1. Introduction State ex rel. Hicks v. Adams Cty....

Jones v. Galloway: Improper Judicial Assignment Creates a Voidable Error (Not a Void Judgment) and Inmates Must Strictly Comply with R.C. 2969.25(A) in Habeas Filings

Date: Apr 16, 2026

Jones v. Galloway: Improper Judicial Assignment Creates a Voidable Error (Not a Void Judgment) and Inmates Must Strictly Comply with R.C. 2969.25(A) in Habeas Filings 1. Introduction In Jones v....

Mandamus Cannot Be Used to Vacate a Conviction by Compelling a Municipal-Court Clerk; Adequate Remedy by Appeal Bars the Writ

Date: Apr 16, 2026

Mandamus Cannot Be Used to Vacate a Conviction by Compelling a Municipal-Court Clerk; Adequate Remedy by Appeal Bars the Writ I. Introduction In State ex rel. Wright v. Clerk of Mun. Court, Slip...

State v. Seymour: But-For Causation in Mixed-Drug Overdose Cases Does Not Require the Defendant’s Drug to Be the Sole Cause

Date: Apr 16, 2026

State v. Seymour: But-For Causation in Mixed-Drug Overdose Cases Does Not Require the Defendant’s Drug to Be the Sole Cause 1. Introduction State v. Seymour (Supreme Court of Ohio, 2026-Ohio-1249)...

State v. Fips (2026-Ohio-1207): License-Status Checks Are Part of a Traffic Stop’s Mission Even After the Original Suspicion Is Dispelled

Date: Apr 9, 2026

State v. Fips (2026-Ohio-1207): License-Status Checks Are Part of a Traffic Stop’s Mission Even After the Original Suspicion Is Dispelled Court: Supreme Court of Ohio | Date: April 7, 2026 |...

Crim.R. 33 Motions Must Be Ruled on Sequentially; Mandamus Lies to Compel a Long-Delayed Ruling on Leave, Not on the New-Trial Motion Itself

Date: Apr 9, 2026

Crim.R. 33 Motions Must Be Ruled on Sequentially; Mandamus Lies to Compel a Long-Delayed Ruling on Leave, Not on the New-Trial Motion Itself Case: State ex rel. Quinn v. Rastatter, Slip Opinion No....

R.C. 2969.25(A)(2) Strict-Compliance Rule: Inmates Must List Case Numbers for Both Prior Civil Actions and Appeals (“Or” Is Inclusive)

Date: Apr 9, 2026

R.C. 2969.25(A)(2) Strict-Compliance Rule: Inmates Must List Case Numbers for Both Prior Civil Actions and Appeals (“Or” Is Inclusive) I. Introduction In State ex rel. Stokes v. Combs, Slip Opinion...