State ex rel. Hall v. Mohr (Slip Opinion), 140 Ohio St. 3d 297

State inmate Hall filed a mandamus action in the Tenth District against Gary Mohr to compel an immediate hearing and release.
Hall attached only a verity affidavit (and a few exhibits) to the complaint, with other required documents missing.
The magistrate found Hall failed to file several required documents under R.C. 2969.25: an affidavit of prior civil actions, an affidavit of indigence, a filing-fee affidavit, and a certified institutional cashier’s statement.
Hall attempted belatedly to cure the deficiencies by filing affidavits after the complaint was filed.
The Tenth District adopted the magistrate’s recommendation, holding that documents must be filed with the complaint and belated cures are ineffective.
The Ohio Supreme Court affirmed, holding that mandatory filing requirements under R.C. 2969.25 cannot be cured by later filings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to file mandatory affidavits under R.C. 2969.25 requires dismissal	Hall argues belated cures should fix defects	Mohr argues missing affidavits must lead to dismissal	Dismissal affirmed; defects cannot be cured

State ex rel. Washington v. Ohio Adult Parole Auth., 87 Ohio St.3d 258 (Ohio 1999) (mandatory filing defects warrant dismissal)
State ex rel. Zanders v. Ohio Parole Bd., 82 Ohio St.3d 421 (Ohio 1998) (reiterates mandatory nature of R.C. 2969.25 requirements)
Fuqua v. Williams, 100 Ohio St.3d 211 (Ohio 2003) (belated affidavits do not excuse noncompliance)