Kneuss v. Sloan (Slip Opinion), 146 Ohio St. 3d 248

Bryan D. Kneuss was convicted in Cuyahoga County in 2013 of aggravated arson and illegal cultivation of marijuana and is serving a four-year sentence.
He did not pursue a direct appeal or file a postconviction petition challenging his convictions or sentence.
In January 2015 Kneuss filed a pro se petition for a writ of habeas corpus in the Eleventh District Court of Appeals asserting: improper bindover, denial of counsel, involuntary guilty plea, actual innocence, ineffective assistance, insufficient evidence/weight, and failure to advise of a right to direct appeal.
The court of appeals dismissed the habeas petition as improper because Kneuss had adequate remedies at law (direct appeal or postconviction relief) and because the petition was defective under Civ.R. 10(A) for lacking a proper caption and party addresses.
Kneuss appealed to the Ohio Supreme Court, which affirmed the appellate court’s dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether habeas corpus is available to challenge trial errors and plea voluntariness	Kneuss: ineffective assistance and lack of counsel rendered plea involuntary and plea/convictions infirm	Warden: habeas lies only to challenge jurisdiction; these are nonjurisdictional claims with adequate remedies at law	Dismissed: habeas not available; claims cognizable on direct appeal or postconviction relief
Whether ineffective-assistance Sixth Amendment claims are cognizable in habeas	Kneuss: counsel failed to present exculpatory evidence making plea involuntary	Warden: ineffective-assistance claims must be raised on direct appeal or postconviction relief, not habeas	Dismissed: ineffective-assistance claims not cognizable in habeas
Whether sufficiency/manifest-weight challenges can be raised in habeas	Kneuss: convictions lack sufficient evidence / are against the weight	Warden: sufficiency/weight are nonjurisdictional and must be raised via appeal/postconviction process	Dismissed: sufficiency/weight claims not cognizable in habeas
Whether an actual-innocence claim allows habeas when other remedies exist	Kneuss: new evidence shows no meth lab and casts doubt on conviction	Warden: actual-innocence claim must be raised through available legal remedies; habeas inappropriate if remedies exist	Dismissed: actual innocence claim barred from habeas because adequate remedies were available

Appenzeller v. Miller, 136 Ohio St.3d 378, 996 N.E.2d 919 (2013) (habeas generally limited to jurisdictional challenges)
Wilson v. Hudson, 127 Ohio St.3d 31, 936 N.E.2d 42 (2010) (ineffective-assistance claims not cognizable in habeas)
Bozsik v. Hudson, 110 Ohio St.3d 245, 852 N.E.2d 1200 (2006) (same: Sixth Amendment claims not for habeas)
State ex rel. Tarr v. Williams, 112 Ohio St.3d 51, 857 N.E.2d 1225 (2006) (sufficiency challenges not cognizable in habeas)
Junius v. Eberlin, 122 Ohio St.3d 53, 907 N.E.2d 1179 (2009) (actual-innocence claims must be raised through available remedies)
State ex rel. O’Neal v. Bunting, 140 Ohio St.3d 339, 18 N.E.3d 430 (2014) (availability of alternative legal remedies precludes habeas relief)
State ex rel. Sherrills v. State, 91 Ohio St.3d 133, 742 N.E.2d 651 (2001) (habeas petition defective if caption/party addresses missing)