Johnson v. Summit Cty. Court of Common Pleas, 2015 Ohio 211

Relator Cinseree Johnson, a designated vexatious litigator, filed an original action for a writ of prohibition against the Geauga County Court of Common Pleas and the Summit County Court Psycho Diagnostic Clinic seeking to enjoin jurisdiction in her ongoing criminal case.
Johnson contended Geauga County lacked territorial jurisdiction because the alleged offenses occurred in Cuyahoga County.
She also challenged a post-trial order requiring a competency evaluation under R.C. 2945.37, arguing such orders are only permissible before trial and only when competency is raised by the defendant.
The panel treated the filing as a request for leave to proceed (required because of her vexatious-litigant status) and reviewed whether the petition stated a viable basis for prohibition.
The majority found the Geauga Court has general subject-matter jurisdiction over felony matters and territorial-jurisdiction questions depend on case-specific facts, making prohibition inappropriate; competency evaluations can be ordered after trial for good cause and do not present a jurisdictional defect.
Leave to proceed was denied because Johnson failed to show reasonable grounds for the action under R.C. 2323.52(F)(2); one judge dissented, arguing the petitions were moot after sentencing and advocating consolidation and appointment of appellate counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Geauga C.P. lacks territorial jurisdiction over charged offenses	Johnson: crimes occurred in Cuyahoga County, so Geauga has no authority	Respondents: common pleas court has general felony jurisdiction; territorial question depends on trial facts	Denied — territorial jurisdiction is a fact-dependent question for the trial court; prohibition inappropriate; appeal available
Whether ordering a competency evaluation after trial exceeds jurisdiction	Johnson: R.C. 2945.37 permits evaluations only before trial and only if defendant raises competency	Respondents: court may order competency evaluation for good cause; issue can be raised sua sponte	Denied — post-commencement evaluations allowed for good cause; such orders are non-jurisdictional and reviewable on appeal
Whether the writ of prohibition is appropriate given available remedies	Johnson: seeks prohibition to enjoin court actions	Respondents: adequate remedy exists by direct appeal of conviction/sentence	Denied — because defects are not patent and unambiguous; appeals are adequate remedy
Whether leave to proceed should be granted to a vexatious litigator	Johnson: filed petitions despite status	Respondents: must show reasonable grounds and no abuse of process	Denied — Johnson failed to show reasonable grounds under R.C. 2323.52(F)(2)

State ex rel. Hummel v. Sadler, 96 Ohio St.3d 84 (jurisdictional defects that are not patent and unambiguous must be resolved by the trial court; writ inappropriate when appeal is available)
Baumgartner v. Duffey, 121 Ohio St.3d 356 (vexatious-litigant restrictions on filing in appellate courts and statutory context)
Diversified Mortgage Investors, Inc. v. Athens Cty. Bd. of Revision, 7 Ohio App.3d 157 (trial courts generally may not take judicial notice of prior separate proceedings)
Mishr v. Poland Bd. of Zoning Appeals, 76 Ohio St.3d 238 (statutory construction: avoid interpretations yielding absurd results)