Boles v. Knab, 129 Ohio St. 3d 222

Boles, proceeding pro se, sought a writ of habeas corpus challenging confinement.
His petition included an affidavit of indigency and sought waiver of court filing fees.
The petition failed to include a six-month inmate account balance certified by the institutional cashier.
R.C. 2969.25(C) requires this six-month balance to accompany indigency filings.
Delayed filing of the required statement is not permitted under the statute.
The Ross County Court of Appeals dismissed the petition for noncompliance, and the Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2969.25(C) requires the six-month inmate account statement.	Boles argues the statute is unconstitutional.	Knab/State maintains the six-month statement is mandatory.	Yes; the six-month statement is mandatory.
Whether delayed submissions are allowed under R.C. 2969.25(C).	Boles sought a delayed statement.	Statute does not permit delayed statements.	Delayed statements are not permitted.
Whether the internal prison policy excuses compliance with R.C. 2969.25(C).	Policy prevented timely compliance.	Policy did not prevent compliance; alternative routing possible.	Policy did not excuse noncompliance.
Whether the petition dismissal was proper given constitutional challenges to the statute.	Challenges to constitutionality should prevail.	Statutes presumed constitutional; no rebuttal shown beyond doubt.	Dismissal proper; statute presumed constitutional.

State ex rel. White v. Bechtel, 99 Ohio St.3d 11 (2003-Ohio-2262) (mandatory filing-fee requirements apply to habeas corpus actions)
State ex rel. McGrath v. McDonnell, 126 Ohio St.3d 511 (2010-Ohio-4726) (R.C. 2969.25 procedures govern indigency filings)
Fuqua v. Williams, 100 Ohio St.3d 211 (2003-Ohio-5533) (no allowance for delayed indigency statements)
Cleveland v. State, 128 Ohio St.3d 135 (2010-Ohio-6318) (statutes presumed constitutional unless proven unconstitutional beyond a reasonable doubt)