State ex rel. Jones v. Woods
2016 Ohio 8342
Ohio Ct. App.2016Background
- Relator Antonio Jones, an inmate at Ross Correctional Institution, filed a petition for postconviction relief in Franklin County Common Pleas Court (case No. 13CR-2345) on June 4, 2015.
- Jones then filed an original action in the Tenth District Court of Appeals on January 13, 2016, seeking a writ of mandamus to compel Judge William H. Woods to rule on that petition.
- Judge Woods filed a certified copy of an entry showing he denied Jones's petition on February 12, 2016.
- Respondent moved for summary judgment in the mandamus action; the magistrate set submission and Jones did not respond to the motion.
- The magistrate recommended granting respondent's motion because the requested act (ruling on the petition) had already been performed.
- The court adopted the magistrate's findings and conclusions, granted summary judgment for respondent, and denied the writ of mandamus.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandamus should compel the judge to rule on the June 4, 2015 postconviction petition | Jones argued the judge had not ruled and thus mandamus was necessary | Woods produced a certified entry showing he denied the petition on Feb. 12, 2016 | No relief — mandamus denied because the judge already ruled |
| Whether summary judgment is appropriate for respondent | Jones did not oppose the motion | Woods argued there is no genuine issue of material fact and moved for summary judgment | Summary judgment granted for respondent |
| Whether mandamus can compel an act already performed | N/A (Jones sought the act) | Woods relied on precedent that mandamus cannot compel completed acts | Court held mandamus unavailable when the act is already performed |
| Whether relator preserved objections to the magistrate's findings | Jones filed no objections to the magistrate's decision | Respondent asserted adoption of magistrate's decision was proper under Civ.R. 53 | Court adopted magistrate's decision; no objections were filed |
Key Cases Cited
- State ex rel. Scruggs v. Sadler, 102 Ohio St.3d 160 (mandamus does not lie to compel an act already performed)
- Turner v. Turner, 67 Ohio St.3d 337 (summary judgment standard)
- Bostic v. Connor, 37 Ohio St.3d 144 (summary judgment standard)
- Harless v. Willis Day Warehousing Co., 54 Ohio St.2d 64 (summary judgment standard)
- Mitseff v. Wheeler, 38 Ohio St.3d 112 (movant bears burden to show no genuine issue of material fact)