Ohio Case Commentaries

Possession Controls: ODRC Must Produce an Inmate’s Master File If It Exists Anywhere in the Department

Date: Feb 19, 2026

Possession Controls: ODRC Must Produce an Inmate’s Master File If It Exists Anywhere in the Department I. Introduction In State ex rel. Lawrence v. Dept. of Rehab. & Corr., Slip Opinion No....

R.C. 149.43(C)(3)(c) “Good-Faith” Bar Applies Only to Whether Fees Are Awarded (and Must Be Timely Raised), Not to Reducing a Fee Amount

Date: Feb 19, 2026

R.C. 149.43(C)(3)(c) “Good-Faith” Bar Applies Only to Whether Fees Are Awarded (and Must Be Timely Raised), Not to Reducing a Fee Amount Case: State ex rel. Platt v. Montgomery Cty. Bd. of Elections,...

State ex rel. Harris v. Watson (2026-Ohio-508) Commentary

Date: Feb 19, 2026

Limited Public-Records Mandamus in Ohio Prisons: “Produce the Record or Certify None Exists,” with Separate Statutory-Damages Awards by Request-Day/Office Commentary on State ex rel. Harris v....

Statutorily Enumerated Misdemeanor Community-Control Conditions Are Reviewed for Abuse of Discretion, Not Under the State v. Jones Three-Part Test

Date: Feb 19, 2026

Statutorily Enumerated Misdemeanor Community-Control Conditions Are Reviewed for Abuse of Discretion, Not Under the State v. Jones Three-Part Test Case: State v. Ballish, Slip Opinion No....

Disbarred Lawyers’ Deed Preparation and “Attorney” Notarization as Distinct UPL Offenses Warranting Per-Act Civil Penalties and Notary Injunctions

Date: Feb 19, 2026

Disbarred Lawyers’ Deed Preparation and “Attorney” Notarization as Distinct UPL Offenses Warranting Per-Act Civil Penalties and Notary Injunctions 1. Introduction In Disciplinary Counsel v. Henderson...

Prior Restraints in Ohio Trial Courts Require an Evidentiary Hearing and Cannot Bar Reporting of Open-Court Information; Media Must Be Heard on Witness Objections (Sup.R. 12)

Date: Feb 18, 2026

Prior Restraints in Ohio Trial Courts Require an Evidentiary Hearing and Cannot Bar Reporting of Open-Court Information; Media Must Be Heard on Witness Objections (Sup.R. 12) I. Introduction State ex...

Passage of Time Alone Is Insufficient to Prove Unreasonable Delay for Ohio Public-Records Statutory Damages; No Duty to Produce Records Not Possessed

Date: Feb 18, 2026

Passage of Time Alone Is Insufficient to Prove Unreasonable Delay for Ohio Public-Records Statutory Damages; No Duty to Produce Records Not Possessed 1. Introduction State ex rel. Fenstermaker v....

Gov.Bar R. I(17) Requires Public Notice of Ohio Bar-Exam Applicants

Date: Jan 31, 2026

Gov.Bar R. I(17) Requires Public Notice of Ohio Bar-Exam Applicants Introduction In 01/29/2026 Administrative Actions, 2026-Ohio-247, the Supreme Court of Ohio issued an administrative...

Cincinnati Bar Assn. v. Eppley (2026-Ohio-160) — “Legal Group” as a Misleading Solo-Practitioner Firm Name; Two-Year Fully Stayed Suspension for Combined Misappropriation-Related Trust Violations, Neglect, UPL, and Misleading Marketing

Date: Jan 27, 2026

“Legal Group” Misleads When No Other Lawyers Practice With the Named Lawyer: Ohio Imposes a Two-Year Fully Stayed Suspension for a Combined Package of Neglect, Trust-Account Misconduct Amounting to...

Disciplinary Counsel v. Wilson (2026-Ohio-165): Fully Stayed Suspension for Client Neglect and Trust-Account Mismanagement, Mitigated by Documented Mental-Health Impairment

Date: Jan 27, 2026

Disciplinary Counsel v. Wilson (2026-Ohio-165): Fully Stayed Suspension for Client Neglect and Trust-Account Mismanagement, Mitigated by Documented Mental-Health Impairment 1. Introduction In...

Email Newsletter Distribution Lists Are Public Records; FERPA/OSPA Require Redaction, Not Blanket Withholding, Absent Proof of Exemption

Date: Jan 27, 2026

Email Newsletter Distribution Lists Are Public Records; FERPA/OSPA Require Redaction, Not Blanket Withholding, Absent Proof of Exemption I. Introduction In State ex rel. Boddy v. Xenia Community City...

Indeterminate 20-to-Life Sentences Create Parole Eligibility Only—Habeas Relief Requires Expiration of the Maximum Term

Date: Jan 22, 2026

Indeterminate 20-to-Life Sentences Create Parole Eligibility Only—Habeas Relief Requires Expiration of the Maximum Term 1. Introduction In re McDonald v. Stuff, Slip Opinion No. 2026-Ohio-150...

R.C. 2335.39 Fee-Shifting Is Unavailable in Mandamus Actions (Ohio Supreme Court, Jan. 21, 2026 Case Announcements)

Date: Jan 22, 2026

R.C. 2335.39 Fee-Shifting Is Unavailable in Mandamus Actions (Ohio Supreme Court, Jan. 21, 2026 Case Announcements) Introduction The Supreme Court of Ohio’s January 21, 2026 “Case Announcements”...

R.C. 101.30 Upheld: Article II, Section 13 “Proceedings” Clause Does Not Constitutionalize Public Access to Legislative Drafting Materials

Date: Jan 22, 2026

R.C. 101.30 Upheld: Article II, Section 13 “Proceedings” Clause Does Not Constitutionalize Public Access to Legislative Drafting Materials Introduction In State ex rel. Prows v. Ohio Legislative...

Crim.R. 33(B) Requires Leave Before an Untimely New-Trial Motion; Failure to Obtain Leave Alone Supports Denial

Date: Jan 22, 2026

Crim.R. 33(B) Requires Leave Before an Untimely New-Trial Motion; Failure to Obtain Leave Alone Supports Denial I. Introduction Case: State v. McAlpin, Slip Opinion No. 2026-Ohio-148 (Supreme Court...

Ohio Supreme Court Reinforces Procedural Gatekeeping: Sua Sponte Habeas Dismissals, Mootness, and Strict Jurisdictional Screening (2026-Ohio-154)

Date: Jan 21, 2026

Ohio Supreme Court Reinforces Procedural Gatekeeping: Sua Sponte Habeas Dismissals, Mootness, and Strict Jurisdictional Screening (2026-Ohio-154) 1. Introduction 01/20/2026 Case Announcements,...

Coercive Sexual Solicitation Plus Implied Judicial Influence Warrants Enhanced Suspension in Ohio Attorney Discipline

Date: Jan 21, 2026

Coercive Sexual Solicitation Plus Implied Judicial Influence Warrants Enhanced Suspension in Ohio Attorney Discipline Introduction In Disciplinary Counsel v. Wallace, Slip Opinion No. 2026-Ohio-112...

R.C. 149.43(G) Limited to Records “Related to That Action”: Unrelated-Case Requests Remain Public-Records Requests; Same-Day, Same-Subject Emails Yield One Statutory-Damages Award

Date: Jan 21, 2026

R.C. 149.43(G) Limited to Records “Related to That Action”: Unrelated-Case Requests Remain Public-Records Requests; Same-Day, Same-Subject Emails Yield One Statutory-Damages Award I. Introduction In...

Same-Day, Same-Recipient, Same-Subject Public-Records Emails Count as One Request for Statutory Damages in Ohio

Date: Jan 21, 2026

Same-Day, Same-Recipient, Same-Subject Public-Records Emails Count as One Request for Statutory Damages in Ohio Case: State ex rel. Henderson v. Washington Court House, Slip Opinion No. 2026-Ohio-110...

CAT Refunds Require Documentary Proof of the Refund “Amount” for Out-of-Ohio Delivery

Date: Jan 17, 2026

CAT Refunds Require Documentary Proof of the Refund “Amount” for Out-of-Ohio Delivery Introduction In Jones Apparel Group/Nine West Holdings v. Harris, Slip Opinion No. 2026-Ohio-74 (Jan. 14, 2026),...