State ex rel. Pruitt v. Donnelly
129 Ohio St. 3d 498
| Ohio | 2011Background
- Pruitt filed a complaint seeking writs of mandamus and prohibition to compel judges to vacate his convictions and sentence.
- Pruitt claimed the sentencing entry language showed he had not pleaded guilty to weapon while under disability and to a firearm specification related to an attempted murder charge.
- The trial court had jurisdiction over the criminal case and sentencing under R.C. 2931.03.
- A sentencing error does not by itself deprive a court of jurisdiction; remedies exist through appeal.
- The court of appeals dismissed Pruitt’s extraordinary-writ claims, and the Supreme Court of Ohio affirmed the dismissal.
- The Court held that Pruitt had adequate remedies in the ordinary course of law to raise his claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does sentencing error deprive jurisdiction? | Pruitt argues lack of guilty pleas removed jurisdiction. | Error in sentencing does not strip jurisdiction; remedy by appeal exists. | No jurisdictional deprivation; writs improper |
| Are mandamus/prohibition appropriate given available appeal remedy? | Relies on extraordinary relief to challenge sentencing. | Adequate remedy by appeal forecloses extraordinary writs. | Adequate remedy by appeal; writs denied |
Key Cases Cited
- State ex rel. Plant v. Cosgrove, 119 Ohio St.3d 264 (Ohio 2008) (adequate remedy by appeal when looking to jurisdiction)
- State ex rel. Cunningham v. Lindeman, 126 Ohio St.3d 481 (Ohio 2010) (adequate remedy by appeal to raise sentencing claims)
- State ex rel. Brooks v. O’Malley, 117 Ohio St.3d 385 (Ohio 2008) (ordinary-writ relief when no adequate appellate remedy)