State ex rel. Ohio Democratic Party v. LaRose (Slip Opinion), 2020 Ohio 1253

On March 16, 2020 the Ohio Department of Health ordered polling-place closures due to COVID-19 risks.
That same night Secretary of State Frank LaRose issued Directive 2020‑06, extending absentee voting through June 1 and moving in‑person voting to June 2; in‑person voting did not occur on March 17.
The Ohio Democratic Party filed an expedited election action seeking a writ of prohibition to invalidate Directive 2020‑06 and to extend absentee-vote deadlines; the Libertarian Party later intervened with similar requests.
The General Assembly enacted emergency 2020 Am. Sub. H.B. No. 197, which voided Directive 2020‑06 and prescribed how the primary would proceed; the secretary of state also rescinded the directive and the governor signed the bill.
Because the secretary rescinded the directive and the legislature enacted governing law for the primary, the court found the parties’ requested relief was no longer live and dismissed the remaining complaint as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Directive 2020‑06 should be invalidated	Directive exceeded authority and must be rescinded; court should order rescission	Directive had been issued to address emergency; secretary could act administratively	Moot — secretary rescinded directive and H.B. 197 voided it, so relief sought is no longer live
Whether the court should direct county boards how to conduct the primary	Court should set procedures in absence of immediate legislative guidance	Secretary and legislature have authority; courts need not suppl[y] them	Moot — legislature enacted H.B. 197 and governor signed it, eliminating the need for court-ordered procedures
Whether H.B. 197 violates federal law (as argued by intervenor)	H.B. 197 conflicts with federal law, so legislative action does not moot the claim	Legislative action is valid and renders the case moot; any federal challenge must be brought separately	Not decided — court declined to adjudicate federal-law challenge and noted it would be for another case/time

Pewitt v. Lorain Corr. Inst., 64 Ohio St.3d 470 (1992) (mootness may be proved by extrinsic evidence)
State ex rel. Gaylor, Inc. v. Goodenow, 125 Ohio St.3d 407 (2010) (a case is moot when issues are no longer live or relief cannot be granted)
Powell v. McCormack, 395 U.S. 486 (1969) (definition of a live controversy/mootness)