State ex rel. Chester Twp. v. Grendell (Slip Opinion), 147 Ohio St. 3d 366

Background

Chester Township Park District was created by Geauga County Probate Court in 1984 under R.C. Chapter 1545; the court sets commissioners and the district is an independent political body.
In 2013 an anonymous review alleged legal noncompliance and mismanagement; Judge Grendell appointed a master commissioner (Mary Jane Trapp) to investigate under R.C. 2101.06.
Master Commissioner Trapp found no intentional misconduct by commissioners but concluded the park district is independent and that township leaders had an incomplete understanding of that independence; she reported the township had eliminated a dedicated inside millage in 2002.
The probate court’s November 26, 2014 entry found the 2002 millage elimination contravened the park district’s independence, directed the park commissioners to secure independent funding by January 2016, found the trustees had a duty to make funds available until independent funding existed (without specifying an amount), ordered revision of the 1993 agreement to conform to R.C. Chapter 1545, and allocated master-commissioner costs.
The township trustees appealed to the Eleventh District, which dismissed their appeal for lack of a final, appealable order; the trustees then sought a writ of prohibition in the Ohio Supreme Court arguing the probate court patently and unambiguously lacked jurisdiction over the trustees.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the probate court patently and unambiguously lacked jurisdiction to issue orders imposing duties/fees on township trustees	Probate (trustees) contended the probate court exceeded its statutory authority under R.C. Chapter 1545 and thus lacked jurisdiction over trustees	Judge Grendell (and amici) argued probate court has authority to enforce its original park-district order and to investigate and correct actions that frustrate the district’s purposes	Court held trustees failed to show a patent and unambiguous lack of jurisdiction; writ denied
Whether the trustees had an adequate remedy at law (necessity for prohibition)	Trustees argued prohibition appropriate because probate court lacked jurisdiction and orders impose obligations on them	Respondent argued appeal is available and was their adequate remedy; prohibition only if jurisdictional defect is patent and unambiguous	Court held an appeal is an adequate remedy; prohibition requires a clear lack of jurisdiction, which was not shown
Scope of probate-court authority over park districts	Trustees argued R.C. Chapter 1545 limits probate court to creation, appointment, removal, and dissolution only	Court and amici argued probate courts have plenary and inherent authority under R.C. 2101.24(C) to investigate and enforce their orders, including supervising entities they create	Court held probate courts have authority to investigate and take actions to enforce the original order; the probate court did not patently lack jurisdiction
Validity of the probate court’s orders reallocating master-commissioner costs and directing funding obligations	Trustees contended assignment of duties/fees to trustees was beyond probate power	Respondent pointed to courts’ broad discretion to appoint masters and allocate costs and to equitable powers to enforce prior orders	Court treated any error as an exercise (not want) of jurisdiction and declined to issue prohibition; appellate remedy remains available

Key Cases Cited

State ex rel. Bell v. Pfeiffer, 131 Ohio St.3d 114 (standard for prohibition requires lack of jurisdiction and no adequate remedy)
State ex rel. Miller v. Warren Cty. Bd. of Elections, 130 Ohio St.3d 24 (same prohibition framework)
Chesapeake Exploration, L.L.C. v. Ohio Oil & Gas Comm., 135 Ohio St.3d 204 (writ may issue only if lack of jurisdiction is patent and unambiguous)
In re Guardianship of Hollins, 114 Ohio St.3d 434 (probate courts are courts of limited jurisdiction)
In re Guardianship of Spangler, 126 Ohio St.3d 339 (probate courts have plenary authority to investigate guardians and exercise inherent powers)
State ex rel. Lewis v. Moser, 72 Ohio St.3d 25 (probate courts’ broad authority may permit remedies not expressly stated in statute)