Henderson v. Ohio Dept. of Rehab. & Corr.
2021 Ohio 2409
| Ohio Ct. Cl. | 2021Background
- Henderson was convicted in two Cuyahoga County cases: a 3-year sentence after revocation in CR-09-520709-A (revoked community control) and an aggregate 9-year sentence in CR-09-530899-A, the latter ordered to run "consecutive to any other sentence."
- Henderson entered ODRC custody on October 6, 2009.
- ODRC auditor Ebony Napier attested to Henderson’s file: 91 days jail credit, 12 days earned credit, and 90 days HB49 credit, yielding a computed release date of March 23, 2021.
- Henderson sued in the Court of Claims for false imprisonment, alleging ODRC improperly ran the 3- and 9-year sentences consecutively and held him beyond his lawful term.
- ODRC moved for summary judgment supported by Napier’s affidavit; Henderson filed a response and cross-motion but submitted several unauthenticated criminal records.
- The Court of Claims found no genuine factual dispute, declined to relitigate the common pleas court’s sentencing order, and granted ODRC summary judgment, denying Henderson’s cross-motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Henderson was falsely imprisoned (term expired before ODRC custody) | Henderson: the trial court erred; sentences should not run consecutively so his lawful term expired earlier | ODRC: sentencing orders required consecutive service; computations (credits and consecutive order) yield release date March 23, 2021 | No false imprisonment; summary judgment for ODRC — lawful confinement continued until Mar. 23, 2021 |
| Whether the Court of Claims can review or void the common pleas sentencing order | Henderson: sentencing entry was "contrary to law" and effectively void | ODRC: Court of Claims lacks jurisdiction to review common pleas criminal sentencing; Henderson did not have the sentence vacated in proper forum | Court declined to review or void the sentencing order here; challenge to sentencing not resolved in Court of Claims |
| Whether Henderson posed admissible evidence creating a genuine issue | Henderson: attached criminal-case documents and asserted sentencing error | ODRC: Napier’s authenticated affidavit controls; Henderson’s attachments were not properly authenticated under Civ.R. 56 | Henderson failed to create a genuine factual dispute; Napier’s affidavit dispositive |
Key Cases Cited
- Gilbert v. Summit Cty., 104 Ohio St.3d 660 (clarifies summary judgment standard)
- Temple v. Wean United, Inc., 50 Ohio St.2d 317 (summary judgment standard and construing evidence for nonmoving party)
- Bennett v. Ohio Dept. of Rehab. & Corr., 60 Ohio St.3d 107 (state liability for prisoners’ false imprisonment; elements of claim)
- Feliciano v. Kreiger, 50 Ohio St.2d 69 (definition of false imprisonment)