State ex rel. Manley v. Walsh (Slip Opinion), 142 Ohio St. 3d 384

Manley, hired as an assistant prosecutor in 2002, claimed he was misclassified and underpaid after a 2003 reorganization.
In January 2003 Walsh purportedly elevated Manley to Chief Counsel, Civil Division, but the county treated him as 50021 with an assistant prosecutor title.
Job descriptions for 50031 (Chief Counsel) and 50021 (unit supervisor) differ, but the record lacks a clear, controlling distinction defining 50031 as a division manager.
Salary scales in 2003 set 50031 range from $84,872 to $106,090; Manley’s salary was $73,730, below that minimum, though above the 50021 midpoint.
Manley alleges pay increases and retirement contributions were improperly calculated due to the misclassification.
Ninth District granted summary judgment for the county; Manley sought mandamus from Ohio Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus was proper where facts about classification are disputed	Manley: duty exists; pay scales control; must pay per 50031.	Walsh: Manley never clearly classified as 50031; title used as working title.	Not clear right; facts disputed; declaratory judgment preferred.
Whether Manley had a clear right to 50031 classification and its salary	Manley performed duties of Chief Counsel, Civil; entitled to 50031 pay scale.	County disputes official/de facto classification and duties.	Right to 50031 and within its salary not shown with certainty.
Whether laches barred relief	Laches not definitive; continuing duty to pay.	Knew of disparity in 2003; waited seven years.	Laches not dispositive here; other remedies available.
Adequacy of ordinary-course remedy	Mandamus appropriate when clear right but facts disputed; declaratory judgment not necessary.	Declaratory judgment in common pleas provides complete relief; mandamus improper.	Adequate remedy in ordinary course; declaratory judgment preferred.
Sanctions for misconduct in proceedings	County engaged in delay tactics and misused App.R. 26; disqualification issues raised.	No abuse; actions within bounds; Rule 26 misapplied in original action.	No abuse of discretion; sanctions denied.

State ex rel. Kabert v. Shaker Hts. City School Dist. Bd. of Edn., 78 Ohio St.3d 37 (1997) (wages/benefits actionable in mandamus when right is clear)
State ex rel. Madden v. Windham Exempted Village School Dist. Bd. of Edn., 42 Ohio St.3d 86 (1989) (amounts must be established with certainty)
State ex rel. Villari v. Bedford Hts., 11 Ohio St.3d 222 (1984) (certainty of relief required in mandamus)
State ex rel. Tempesta v. Warren, 128 Ohio St.3d 463 (2011) (certainty and proof standards in mandamus)
State ex rel. Hamlin v. Collins, 9 Ohio St.3d 117 (1984) (definition of certainty in relief; monetary claims)
State ex rel. Bossa v. Giles, 64 Ohio St.2d 273 (1980) (declaratory judgment when complete remedy available)
State ex rel. Viox Builders, Inc. v. Lancaster, 46 Ohio St.3d 144 (1989) (declaratory judgment as adequate remedy when complete relief provided)
State ex rel. Fenske v. McGovern, 11 Ohio St.3d 129 (1984) (when declaratory judgment not enough, injunctive relief considered)
State ex rel. Andrews v. Chardon Police Dept., 2013-Ohio-4772 (Ohio) (appellate practice and Rule interpretations in original actions)
State ex rel. Brock v. Moore, 2013-Ohio-70 (Ohio) (procedural aspects of original actions in courts of appeals)
State ex rel. Phillips v. Irwin, 774 N.E.2d 1218 (2002) (application of original actions and reconsideration principles)