Galluzzo v. Braden, 2012 Ohio 3980

Galluzzo, pro se, filed a civil rights complaint in the Champaign County Court of Common Pleas against Braden, Sampson, and Garrison for alleged zoning overreach and privacy/property rights invasion.
He sought damages up to $500,000 for time lost and mental/emotional harm.
Galluzzo moved to waive filing costs, asserting current Social Security and other public assistance income.
The court sent an indigency form; Galluzzo filed an Affidavit of Indigency listing $690 monthly SS income, $210 monthly child support, $480 net income, $782.60 monthly expenses, and $830 in assets.
Defendants moved to dismiss based on immunity; Galluzzo then filed a Notice of Voluntary Dismissal claiming out-of-state status.
The trial court later held Galluzzo was not indigent for purposes of costs and ordered costs at a minimum rate of $10 per month (total costs around $292).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court properly denied indigency and ordered costs	Galluzzo contends indigency undisputed and total circumstances warrant waiver	Court may discretionary deny indigency; costs justified	Trial court correctly denied waiver and set monthly costs
Whether pro se status affects court treatment of indigency and costs	Galluzzo argues leniency due to self-representation	Pro se status does not entitle leniency or special treatment	Pro se status does not compel leniency; standard applied was proper
Whether the amount and method of cost repayment were reasonable	Costs should be waived or structured differently given indigent status	Minimum $10/month payment with extended period is reasonable	Order to pay at least $10/month over time was reasonable

Wilson v. Dept. of Rehab. & Corr., 138 Ohio App.3d 239 (10th Dist. 2000) (courts may consider indigency criteria and resource allocation)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard for indigency decisions)