In re Smith, 2018 Ohio 448

Relator John A. Smith, a federal inmate at USP Canaan, was charged in Youngstown Municipal Court in Oct. 2014 with two first-degree misdemeanors and pleaded not guilty.
At a November 2014 pretrial Smith waived statutory time limits and the court reset a pretrial for Jan. 12, 2015; Smith was arrested on federal charges in Dec. 2014 and did not appear for the Jan. 2015 pretrial.
The municipal court issued an arrest warrant after Smith’s nonappearance; Smith later sought to set aside the warrant or enter a guilty plea in absentia—both requests were denied.
In Nov. 2017 Smith moved in the municipal court for a disposition of the pending charges; the court denied that motion and Smith filed a petition for a writ of mandamus in this court seeking an order compelling prompt final disposition.
The City (respondent) objected, arguing mandamus was not appropriate; the court found Smith had adequate remedies at law and dismissed the mandamus petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus should compel the municipal judge to promptly dispose of pending charges	Smith asked the court to order Judge Kobly to provide a prompt, final disposition	City argued mandamus was inappropriate because other adequate remedies exist	Denied — mandamus dismissed for lack of entitlement
Whether the Interstate Agreement on Detainers (IAD) or related procedures provide an adequate remedy	Smith asserted the IAD supports his right to prompt disposition while incarcerated out of state	City pointed to the IAD and its procedures as an available remedy	Court held the IAD provides an adequate remedy at law
Whether Smith’s November 2017 motion and its pending direct appeal provide an adequate remedy	Smith relied on his in-court motion for disposition	City noted Smith appealed the denial of that motion to this court	Court held the existing motion and direct appeal constitute an adequate remedy

State ex rel. Brown v. Ashtabula Cty. Bd. of Elections, 142 Ohio St.3d 370 (2014) (mandamus is an extraordinary remedy to be narrowly applied)
State ex rel. Taxpayers for Westerville Schools v. Franklin Cty. Bd. of Elections, 133 Ohio St.3d 153 (2012) (elements required to obtain a writ of mandamus)