2016 Ohio 3309
Ohio2016Background
- Mateo Ralios, an inmate convicted of aggravated vehicular homicide, aggravated vehicular assault, and receiving stolen property, was the subject of a demand by the Ohio Attorney General’s Collections Enforcement Section to reimburse the Crime Victims Reparations Fund for payments to the victim.
- The Fund had paid $46,385.66 to the victim; the Attorney General sought reimbursement under R.C. 2743.72.
- Ralios filed a petition for a writ of prohibition in the Tenth District Court of Appeals seeking to prevent enforcement of the reimbursement demand.
- The magistrate recommended dismissal because Ralios failed to attach the six‑month inmate account statement required by R.C. 2969.25(C)(1) when seeking a fee‑waiver; Ralios filed no objections to the magistrate’s decision.
- The Tenth District adopted the magistrate’s findings and dismissed the complaint; Ralios appealed to the Ohio Supreme Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ralios complied with R.C. 2969.25(C)(1) filing requirements to seek waiver of filing fees | Ralios did not provide the required six‑month inmate account statement but implicitly sought waiver | Iannotta asserted dismissal was proper for noncompliance with the mandatory statutory filing requirement | Court held Ralios failed to attach the required statement and dismissal was proper (statutory requirement is mandatory) |
| Whether failure to object to a magistrate’s decision forfeits issues on appeal | Ralios did not object to the magistrate below and therefore preserved nothing for review | Iannotta argued failure to object waived all but plain error | Court held Ralios waived all but plain error by not objecting; nothing met plain‑error standard |
| Whether Ralios could raise on appeal that the criminal sentencing entry waived costs/fees and restitution | Ralios argued the sentencing judgment waived costs and did not order restitution, so reimbursement was improper | Iannotta argued the issue was not raised below and, in any event, R.C. 2743.72 allows reimbursement without a restitution order once the Fund paid and defendant was convicted | Court held Ralios forfeited the argument by not raising it below and, on the merits, R.C. 2743.72 supports reimbursement even absent a restitution order |
| Whether the Attorney General is authorized to seek reimbursement from Ralios | Ralios contended Iannotta was not authorized by law to seek reimbursement | Iannotta maintained statutory authority under R.C. 2743.72 to recover Fund payments after conviction | Court held the Attorney General is authorized to seek reimbursement under applicable statute and precedent |
Key Cases Cited
- Boles v. Knab, 129 Ohio St.3d 222 (mandatory compliance with R.C. 2969.25; failure to comply subjects inmate action to dismissal)
- State ex rel. White v. Bechtel, 99 Ohio St.3d 11 (R.C. 2969.25 requirements are mandatory)
- State ex rel. McGrath v. McDonnell, 126 Ohio St.3d 511 (failure to comply with R.C. 2969.25 supports dismissal)
- State ex rel. Wilson v. Indus. Comm., 100 Ohio St.3d 23 (procedural requirements for preserving objections to magistrate findings)
- Portage Cty. Bd. of Commrs. v. Akron, 109 Ohio St.3d 106 (issues not raised below are forfeited on appeal)
- Ohio Crime Victims Reparations Fund v. Dalton, 152 Ohio App.3d 618 (R.C. 2743.72 permits reimbursement by the state absent a restitution order once Fund paid and defendant was convicted)