State ex rel. Littlepage v. Deters (Slip Opinion), 148 Ohio St. 3d 507

Daniel Littlepage was indicted for murder and aggravated murder with firearm specifications; he pleaded guilty to aggravated murder and was sentenced to 99 years to life plus a consecutive 3-year firearm specification.
After direct appeal and denial of postconviction relief (both affirmed), Littlepage sought additional discovery in July–August 2015 and filed motions to compel.
In January 2016 Littlepage filed a mandamus petition in the First District Court of Appeals seeking a writ to compel Hamilton County Prosecutor Joseph Deters to produce discovery (and originally sought trial counsel’s file, which was later mailed to him).
The court of appeals dismissed the mandamus action, concluding the issues were previously decided on appeal and that mandamus was improper.
The Ohio Supreme Court reviewed whether mandamus was available to compel discovery after the time allowed by Crim.R. 16 and whether Littlepage lacked an adequate legal remedy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus can compel the prosecutor to produce discovery after trial and after Crim.R. 16 deadlines	Littlepage sought a writ ordering Deters to produce discovery now	Deters argued Crim.R. 16 governs discovery timing and permits motions only before trial; no duty to produce now	Mandamus denied: Crim.R. 16 limits discovery timing to pretrial; no present duty to produce discovery
Whether petitioner demonstrated a clear legal right and respondent a clear duty to provide discovery	Littlepage asserted a right to the requested materials	Deters and court said no clear legal duty exists outside Crim.R. 16’s timetable	Petitioner failed to show clear right or respondent’s clear duty; burden not met
Whether mandamus is appropriate given alternative remedies	Littlepage claimed mandamus necessary to obtain discovery	Deters argued appeal from trial-court rulings is an adequate remedy	Mandamus inappropriate because appeal from trial-court discovery rulings is an adequate remedy
Mootness of claim against trial counsel for turning over file	Littlepage sought counsel’s file in petition	Respondent counsel had mailed the file to Littlepage in January 2016	Claim against counsel is moot; no relief required

State ex rel. Waters v. Spaeth, 131 Ohio St.3d 55 (2012) (mandamus elements; petitioner must prove entitlement by clear and convincing evidence)
State ex rel. Dillon v. Cottrill, 145 Ohio St.3d 264 (2016) (availability of an appeal from trial-court rulings is an adequate remedy precluding mandamus)