State ex rel. Lorain Cty. Bd. of Commrs. v. Lorain Cty. Court of Common Pleas (Slip Opinion), 2015 Ohio 3704

Prohibition writ sought to prevent Lorain County Court of Common Pleas from enforcing orders directing the Board of Commissioners to appropriate funds to the sheriff for courthouse security.
Former Administrative Judge Burge issued an August 27, 2014 order directing an appropriation of $124,953.20 for security; after Burge’s removal, Administrative Judge Betleski issued an October 3, 2014 order giving the commissioners an option to appropriate funds to the court to pass to the sheriff.
There was no pending lawsuit or actual case between the sheriff and the commissioners before the Lorain County Court of Common Pleas regarding funding; the dispute was informal and among sheriff, commissioners, and the court.
The Lorain County PSA identified security deficiencies at the old courthouse and PIU; sheriff provided cost estimates for security, with various funding options discussed.
The trial court’s orders were challenged as jurisdictionally void; this Court granted the writ of prohibition, concluding there was no jurisdiction to issue such funding orders absent a case or controversy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court had jurisdiction to issue funding orders absent a case or controversy	Commissioners: there is a dispute warranting judicial resolution	Betleski/Burge: orders were within judicial powers to resolve funding disputes	Lack of jurisdiction; no case or controversy
Whether the orders were administrative or judicial in nature	Commissioners: court acteds administratively to fund security	Judges: orders were attempts to resolve funding dispute, not mere administration	Orders not administrative; unauthorized judicial action
Whether the commissioners have an adequate remedy at law to challenge the orders	There is no adequate remedy if orders stand	Remedy via contempt or mandamus is unavailable since funds were to sheriff, not court	No adequate remedy at law; writ granted

State ex rel. Barclays Bank, P.L.C. v. Hamilton Cty. Court of Common Pleas, 74 Ohio St.3d 536 (1996) (actual controversy required for relief; absence voids jurisdiction)
In re Furnishings & Equip. for Judge, Courtroom & Personnel for Courtroom Two, 66 Ohio St.2d 427 (1981) (administrative vs judicial order distinction; contempt available)
State ex rel. Avellone v. Lake Cty. Bd. of Commrs., 45 Ohio St.3d 58 (1989) (judicial power limits; administrative actions distinguished)
State ex rel. Britt v. Franklin Cty. Bd. of Commrs., 18 Ohio St.3d 1 (1985) (administrative vs judicial function framework)