State ex rel. Chappell v. Mahoning Cty. Coroner Office
2017 Ohio 881
| Ohio Ct. App. | 2017Background
- Relator Ronald Chappell filed an emergency/peremptory writ of mandamus seeking to force the Mahoning County Coroner to take custody of his deceased mother’s body and perform an autopsy before a scheduled cremation.
- Chappell alleged he filed a police report claiming "foul play" and that law enforcement should have notified the coroner under R.C. 313.12(A).
- Chappell states he personally contacted the coroner’s office on March 7 and March 8, 2017, requesting an autopsy.
- The coroner determined, in the exercise of discretion, that the death appeared natural and an autopsy was unnecessary under R.C. 313.131(B).
- The petition sought mandamus to compel the coroner to take possession of the body and perform an autopsy; the court reviewed whether the facts were uncontroverted and whether mandamus could override the coroner’s discretionary decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether coroner was required to be notified of suspicious death | Chappell: law enforcement should have contacted coroner under R.C. 313.12(A) | Coroner: notification requirement satisfied; coroner need not perform autopsy on notification alone | Court: R.C. 313.12(A) requires only notification, not mandatory autopsy |
| Whether mandamus can compel coroner to perform autopsy | Chappell: coroner must perform autopsy because of alleged suspicious circumstances | Coroner: decision to autopsy is discretionary under R.C. 313.131(B) and was exercised to decline autopsy | Court: Mandamus cannot control discretionary decisions absent abuse of discretion; relator failed to show entitlement |
Key Cases Cited
- State ex rel. Highlander v. Rudduck, 816 N.E.2d 213 (Ohio 2004) (peremptory writ available only when facts uncontroverted and entitlement beyond doubt)
- State ex rel. Zimmerman v. Tompkins, 663 N.E.2d 639 (Ohio 1996) (elements required for mandamus: clear right, clear duty, and lack of adequate remedy)
- State ex rel. Brown v. Ashtabula Cty. Bd. of Elections, 31 N.E.3d 596 (Ohio 2014) (mandamus is extraordinary and should be granted cautiously)
- State ex rel. Husted v. Brunner, 914 N.E.2d 397 (Ohio 2009) (mandamus cannot control discretionary acts absent abuse of discretion)
- City of Cleveland ex rel. Neelon v. Locher, 266 N.E.2d 831 (Ohio 1971) (courts cannot direct how an official exercises discretion)
- Owens v. Anderson, 530 N.E.2d 942 (Ohio App.) (coroner has discretion regarding autopsies)