Robinson v. Fender (Slip Opinion), 2020 Ohio 458

On March 25, 2019, Jackie N. Robinson filed a petition for a writ of habeas corpus seeking immediate release, alleging his sentences had expired.
Ohio law (R.C. 2969.25(A)) requires an inmate who sues or appeals against a governmental entity to file an affidavit describing each civil action the inmate filed in the prior five years, including case details and outcomes.
Robinson attached an affidavit stating he could not recall all civil actions from the prior five years and therefore did not list them; the affidavit contained no case names, numbers, courts, parties, or outcomes.
The Eleventh District Court of Appeals dismissed Robinson’s habeas petition for failure to comply with R.C. 2969.25(A), concluding the affidavit made no attempt to satisfy the statute.
Robinson appealed to the Ohio Supreme Court, which affirmed the dismissal and also denied his separate motion for certified copies of trial-court records he requested in this habeas action.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to comply with R.C. 2969.25(A) permits dismissal of the habeas petition	Robinson did not contest noncompliance on appeal; he argued his sentences expired due to missing jail-time credit	Warden urged dismissal because Robinson failed to file the statutorily required affidavit listing prior civil actions	Court: Dismissal affirmed; compliance with R.C. 2969.25(A) is mandatory and failure warrants dismissal
Whether Robinson’s submitted affidavit satisfied R.C. 2969.25(A)	Robinson asserted inability to recall prior suits and asked for due process despite procedural fault	Warden argued affidavit contained none of the required information and reflected no attempt to comply	Court: Affidavit insufficient; no attempt to comply; strict compliance required
Whether Robinson could obtain certified copies of trial-court records via this habeas action	Robinson requested certified copies of records, journal entries, and indictments from his criminal case	Warden argued the trial court is not a party here and habeas is not the proper vehicle for obtaining court records	Court: Motion denied; records sought are trial-court documents and access is not obtained through habeas; other remedies govern access

State v. Henton, 50 N.E.3d 553 (Ohio 2016) (compliance with R.C. 2969.25(A) is mandatory and requires strict compliance)
State ex rel. Manns v. Henson, 894 N.E.2d 47 (Ohio 2008) (statute demanding strict compliance with affidavit requirements)
State ex rel. Swanson v. Ohio Dept. of Rehab. & Corr., 128 N.E.3d 193 (Ohio 2019) (omission of a prior action from the affidavit warrants dismissal)
State ex rel. Nye v. Coates, 57 N.E.3d 1138 (Ohio 2016) (writ cannot issue against a nonparty official)
State ex rel. Harris v. Pureval, 121 N.E.3d 337 (Ohio 2018) (habeas is not the proper vehicle to obtain court records; mandamus governs access)