State ex rel. Martin v. Buchanan (Slip Opinion), 152 Ohio St. 3d 68

Tramaine E. Martin was convicted in Cleveland Heights Municipal Court on multiple counts and appealed; the Eighth District dismissed the appeal for lack of a final, appealable order.
Martin petitioned the Eighth District for a writ of mandamus compelling Judge A. Deane Buchanan to issue a final, appealable order in the underlying criminal case.
Martin alternatively sought a writ of prohibition against the Cleveland Heights clerk of courts, alleging the clerk improperly applied bail posted in a separate case to fines and costs in the earlier case.
The court of appeals denied mandamus because Judge Buchanan had scheduled a hearing addressing finality, providing an adequate remedy at law.
The court of appeals denied prohibition because the depositor had consented to the disposition of the funds and the clerk’s actions were not judicial or quasi‑judicial.
While the appeal to the Supreme Court of Ohio was pending, Judge Buchanan entered a new judgment entry; the Supreme Court found Martin’s mandamus claim moot and held prohibition unavailable because the clerk’s actions were not judicial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus could compel the judge to issue a final, appealable order	Martin: Judge Buchanan failed to enter a final order; mandamus is needed to obtain one	Judge/State: A hearing had been scheduled addressing finality; an adequate remedy at law exists	Mandamus is moot here because the judge later entered a new judgment; mandamus would not lie to compel an act already performed
Whether prohibition could bar the clerk from applying posted bail to fines/costs	Martin: Clerk fraudulently applied bail from an unrelated case to outstanding fines/costs	Clerk/Court: Depositor consented to disposition; clerk’s actions were administrative, not judicial	Prohibition denied because the clerk did not exercise judicial or quasi‑judicial power
Whether the clerk’s billing/collection is a judicial act allowing prohibition	Martin: Actions effectively adjudicated or altered rights requiring judicial authority	Clerk: Billing/collection is administrative ministerial work, not exercise of judicial power	Court held billing/collection is not judicial or quasi‑judicial; prohibition does not lie
Whether Martin’s motion to proceed to judgment remained ripe	Martin: Sought to advance judgment while appeal pending	Respondents: Subsequent events rendered motion moot	Motion to proceed to judgment denied as moot

State ex rel. Eubank v. McDonald, 135 Ohio St.3d 186, 2013-Ohio-72, 985 N.E.2d 463 (mandamus will not lie to compel an act already performed)
State ex rel. Elder v. Camplese, 144 Ohio St.3d 89, 2015-Ohio-3628, 40 N.E.3d 1138 (elements required for a writ of prohibition)
State ex rel. Dayton Law Library Assn. v. White, 163 Ohio App.3d 118, 2005-Ohio-4520, 836 N.E.2d 1232 (billing and attempted collection by a municipal‑court clerk is not the exercise of judicial or quasi‑judicial authority)