State ex rel. Peoples v. Schneider (Slip Opinion), 150 N.E.3d 946

In 2002 Peoples was convicted of aggravated murder with two firearm specifications; the indictment also included a having-a-weapon-while-under-disability (WUD) count, but the 2002 sentencing entry did not reference the WUD count.
The Tenth District affirmed his convictions and sentence on direct appeal.
In November 2018 Peoples moved in the trial court for a final, appealable order, arguing the 2002 sentencing entry was void for failing to dispose of the WUD count; the trial court denied the motion and Peoples did not appeal that denial.
In March 2019 Peoples filed a mandamus complaint in the Tenth District against Judge Charles Schneider seeking an order correcting the 2002 entry and a new sentencing hearing.
The Tenth District, adopting a magistrate’s recommendation, dismissed the mandamus complaint under Civ.R. 12(B)(6) on grounds that Peoples had an adequate remedy at law and that res judicata barred the claim given his prior appeals raising the same issue.
The Supreme Court of Ohio affirmed, holding Peoples’s claim is barred by res judicata and that he had an adequate remedy in the ordinary course of law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does res judicata bar Peoples’s mandamus claim that the 2002 sentencing entry is not final because it omitted the WUD count?	Peoples: the sentencing entry is void and not final; he is entitled to mandamus to correct it.	Schneider/State: Peoples previously litigated the same claim; a valid final judgment on the merits bars relitigation.	Court: Res judicata bars the claim; he raised the issue repeatedly and it was previously resolved.
Does Peoples lack an adequate remedy at law, making mandamus appropriate?	Peoples: no adequate remedy because the sentencing entry is void and needs correction via extraordinary writ.	Schneider/State: Peoples had adequate remedies (direct appeal, prior mandamus petitions, and could have appealed the 2018 denial).	Court: Peoples had adequate remedies in the ordinary course of law; mandamus is not available.

Grava v. Parkman Twp., 73 Ohio St.3d 379 (1995) (defines res judicata: a final judgment bars subsequent actions on claims arising from same transaction or occurrence)
State ex rel. Denton v. Bedinghaus, 98 Ohio St.3d 298 (2003) (applies res judicata in mandamus context)
State ex rel. Crabtree v. Franklin Cty. Bd. of Health, 77 Ohio St.3d 247 (1997) (materials incorporated by reference become part of complaint for Civ.R. 12(B)(6) review)
State ex rel. Brown v. Nusbaum, 152 Ohio St.3d 284 (2017) (de novo review of Civ.R. 12(B)(6) dismissal in mandamus proceedings)
State ex rel. Zander v. Judge of Summit Cty. Common Pleas Court, 156 Ohio St.3d 466 (2019) (standard for dismissal under Civ.R. 12(B)(6))
State ex rel. Daniels v. Russo, 156 Ohio St.3d 143 (2018) (a trial-court order denying a motion for a final, appealable order can itself be a final, appealable order)
State ex rel. Peoples v. Johnson, 152 Ohio St.3d 418 (2017) (previous mandamus petition by Peoples; court held he had pursued adequate remedies)
Jackson v. Johnson, 135 Ohio St.3d 364 (2013) (holding that an adequate remedy at law defeats mandamus even if the relator did not pursue it)