State Ex Rel. Bell v. Madison County Board of Commissioners, 9 N.E.3d 1016

Bell and attorney Cramer filed a mandamus petition in the Madison County Court of Appeals seeking compliance with R.C. 163.01 and 163.02 and due process in a sewer easement dispute arising from a 2003 appropriation action.
The underlying 2003 appropriation case against Bell and his wife resulted in a judgment that the board was entitled to an easement, affirmed on appeal.
The Madison County Court of Appeals dismissed Bell’s mandamus petition, a decision this court later affirmed in State ex rel. Bell v. Madison Cty. Bd. of Commrs., 128 Ohio St.3d 357, 2011-Ohio-527.
Following that, the board sought sanctions under R.C. 2323.51 for frivolous conduct related to the mandamus action and the court awarded $21,137.19 in fees.
Bell and Cramer appealed the sanctions, arguing the court of appeals abused its discretion in awarding them; the Supreme Court ultimately affirmed sanctions.
The court concluded the mandamus action was frivolous, the board was adversely affected, and the fee award was reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court of appeals abuse its discretion in sanctions?	Bell	Board	No abuse; sanctions warranted
Are the sanctions supported by adverse effects and reasonable fees?	Bell	Board	Yes; fees reasonable and board adversely affected
Was discovery denial a due-process violation in sanctions proceedings?	Bell	Board	No due-process violation; discovery not required

State ex rel. Striker v. Cline, 130 Ohio St.3d 214 (2011-Ohio-5350) (abuse-of-discretion standard for sanctions)
State ex rel. Bell v. Madison Cty. Bd. of Commrs., 128 Ohio St.3d 357 (2011-Ohio-527) (precedent affirming dismissal and sanctions context)
Bittner v. Tri-County Toyota, Inc., 58 Ohio St.3d 143 (1991) (starting point for calculating attorney fees; hours times rate)
State ex rel. Bell v. Madison Cty. Bd. of Commrs., 139 Ohio St.3d 106 (2014-Ohio-1564) ( supreme court affirming sanctions for frivolous conduct)