State ex rel. Longville v. Akron, 2013 Ohio 1161

Patricia Longville filed a complaint under R.C. 733.59 seeking declaratory judgment and injunctive relief against the City of Akron over campaign-contribution limits under the Akron Charter and ordinances.
Longville sought to declare a $100 per candidate limit for ward candidates and $300 per candidate limit for at-large/mayoral candidates, and to enjoin donors accordingly.
The City answered, denying relief and contending Longville failed to state a claim.
Longville moved for summary judgment; the trial court denied declaratory judgment/injunctive relief but granted a writ of mandamus directing the city law director to enforce the donation limits.
The City appealed; Longville cross-appealed for attorney fees, which the trial court denied on the merits of the mandamus issue.
The appellate court held that mandamus was improper based on lack of standing and reversed the judgment, remanding for further proceedings consistent with the decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court err by converting the action into mandamus?	Longville contends the case remained a declaratory/injunctive action and not mandamus.	Akron contends the court properly treated and granted mandamus relief based on the pleadings.	Yes; mandamus was improper due to lack of standing.
Did Longville have standing to pursue a common-law taxpayer action requiring mandamus or enforcement relief?	Longville asserts she has standing to seek court enforcement of campaign-law provisions.	Akron asserts Longville lacked the requisite standing to bring a common-law taxpayer action.	No; Longville lacked standing to file a common-law taxpayer action.

State ex rel. Masterson v. Ohio State Racing Comm., 162 Ohio St. 366 (1954) (taxpayer lacks standing to enjoin expenditures absent statutory authority or special interest)
State ex rel. Dann v. Taft, 110 Ohio St.3d 1 (2006) (taxpayer relief may be sought to prevent illegal expenditure, but requires standing)
State ex rel. Citizens for a Better Portsmouth v. Sydnor, 61 Ohio St.3d 49 (1991) (security prerequisite for statutory taxpayer action)
Dresher v. Burt, 75 Ohio St.3d 280 (1996) (Dresher outlines summary judgment standard and burden-shifting)
Temple v. Wean United, Inc., 50 Ohio St.2d 317 (1977) (summary judgment standard and evidentiary burden on movant)
Grafton v. Ohio Edison Co., 77 Ohio St.3d 102 (1996) (de novo review of summary judgment; proper appellate standard)