Mansaray v. State, 138 Ohio St. 3d 277

Mansaray convicted in 2010 for drug offenses; marshals entered his home to find Rodney Williams and found ecstasy instead, leading to his 11-year sentence.
Appellate court later reversed the convictions, holding the search warrant did not authorize Mansaray’s house search; charges were dismissed and he was released on bond.
Mansaray filed a RC 2743.48 civil action alleging wrongful imprisonment due to a procedural error; trial court dismissed, then the court of appeals reversed.
The central legal issue is the meaning and application of RC 2743.48(A)(5) regarding a post-sentencing error in procedure.
The Supreme Court held that the fifth element requires the error to occur after sentencing and during or after imprisonment, which did not happen here; Mansaray is not a wrongfully imprisoned individual, and the appeals court decision is reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RC 2743.48(A)(5) requires post-sentencing error to have occurred after imprisonment	Mansaray contends error could be a pre-sentencing procedural flaw later deemed to have caused release	The State argues the error must occur after sentencing and during/imprisonment, per statute’s language	True; error must occur after sentencing during/imprisonment.

Doss v. State, 135 Ohio St.3d 211 (2012-Ohio-5678) (establishes all elements of RC 2743.48 must be proven by preponderance)
Coventry Towers, Inc. v. Strongsville, 18 Ohio St.3d 120 (1985) (statutory language interpreted plainly and unambiguously)
Youngstown Club v. Porterfield, 21 Ohio St.2d 83 (1970) (aids in statutory construction of phrases modifying nearby terms)