State ex rel. Edward Smith Corp. v. Marsh, 2024 Ohio 201

Edward Smith, an inmate convicted of murder in 1999, filed a writ of prohibition in Ohio's First District Court of Appeals.
Smith argued that his conviction was invalid due to alleged lack of subject-matter jurisdiction by the trial court, claiming he should have been tried in a housing division, not the general division.
He also made assertions about unlawful property entry and claimed (without clarity) to be a corporation tried in absentia.
The named defendants included a judge, a former prosecutor, and an FBI agent.
The appellate court found the complaint incomprehensible and dismissed it for failure to state a claim; Smith’s subsequent motion to amend was denied as untimely.
The Supreme Court of Ohio reviewed Smith’s appeal on the dismissal and denial of leave to amend.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Complaint for Prohibition	Smith alleges lack of jurisdiction and improper trial division	Complaint is incomprehensible and lacks a cognizable claim	Dismissal affirmed; no claim stated
Jurisdiction over Felony Cases	Only housing division had jurisdiction over Smith’s charges	General division has subject matter jurisdiction over felony	General division had proper jurisdiction
Standing/Relief Sought Against Defendants	Judge and officials acted beyond authority	No facts alleged showing improper exercise of judicial power	No grounds to grant prohibition
Right to Amend After Dismissal	Denial of opportunity to amend was improper	Motion to amend was filed after dismissal	Denial of amendment was proper post-dismissal

State ex rel. Reynolds v. Kirby, 172 Ohio St.3d 273 (Ohio 2023) (sets out requirements for writ of prohibition)
State ex rel. Hemsley v. Unruh, 128 Ohio St.3d 307 (Ohio 2011) (standard for dismissing writ for failure to state a claim)
Smith v. Sheldon, 157 Ohio St.3d 1 (Ohio 2019) (confirms subject-matter jurisdiction of common pleas court over felonies)