Davis v. Hill (Slip Opinion), 2022 Ohio 485

James A. Davis was convicted in 1997 of multiple felonies (rape, kidnapping, felonious assault) and sentenced to an aggregate term of 104 to 155 years; those convictions were previously affirmed on appeal.
In February 2021 Davis filed a petition for a writ of habeas corpus in the court of appeals, alleging prosecutorial suppression (Brady) and that the trial court wrongly denied a new‑trial motion.
At filing Davis paid the full $200 filing fee (initial $108, then the remaining $92 shortly after); the clerk initially noted $200 due.
The warden moved to dismiss; the court of appeals dismissed the petition both for Davis’s alleged failure to comply with R.C. 2969.25(C) (affidavit of indigency when seeking waiver) and for failing to state a claim cognizable in habeas corpus.
The Ohio Supreme Court reviewed de novo, held dismissal for noncompliance with R.C. 2969.25(C) was erroneous because Davis paid the full fee, but affirmed dismissal on the merits because habeas relief was not available for Davis’s claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2969.25(C) noncompliance warranted dismissal	Davis paid the full filing fee and did not seek a fee waiver	Court of appeals treated petition as noncompliant with R.C. 2969.25(C)	R.C. 2969.25(C) applies only when seeking a fee waiver; dismissal on that ground was error
Whether the petition stated a claim cognizable in habeas corpus	Alleged Brady suppression and trial‑court error justify habeas relief	Habeas is limited to cases where maximum sentence expired or where court lacked subject‑matter jurisdiction	Petition failed: Davis’s sentence has not expired and alleged errors are nonjurisdictional; habeas unavailable
Whether the current warden is a proper party	(no separate argument)	Court substituted current warden under court practice rule	Current warden automatically substituted as respondent

Brady v. Maryland, 373 U.S. 83 (1963) (suppression‑of‑evidence rule alleged by petitioner)
Leyman v. Bradshaw, 146 Ohio St.3d 522 (2016) (habeas corpus available generally only when maximum sentence expired)
Stever v. Wainwright, 160 Ohio St.3d 139 (2020) (habeas appropriate when sentencing court lacked subject‑matter jurisdiction)
Kneuss v. Sloan, 146 Ohio St.3d 248 (2016) (habeas not available for nonjurisdictional errors when an adequate remedy exists)
State ex rel. Evans v. McGrath, 151 Ohio St.3d 345 (2017) (noncompliance with R.C. 2969.25(C) can justify dismissal of inmate actions)
Smith v. Sheldon, 157 Ohio St.3d 1 (2019) (common pleas courts have subject‑matter jurisdiction over felonies)
State ex rel. Norris v. Wainwright, 158 Ohio St.3d 20 (2019) (de novo review standard for habeas dismissal)