State ex rel. Richard v. Mohr, 2013 Ohio 1471

Calo and Jolly petition for mandamus seeking parole hearings on a fixed schedule; Richard is a relator in related matter but not participating on appeal.
Appellees are Mohr (Director), Hageman (parole authority chief), and Mausser (parole board chair).
Court of appeals dismissed the mandamus action; Calo and Jolly appeal to the Supreme Court of Ohio.
They argue they are entitled to parole hearings under a former Ohio Admin. Code provision implementing a five-year/annual hearing cadence.
The Court clarifies inmates have no constitutional or statutory entitlement to parole or to a particular parole-date or docket.
The court ultimately affirms the appellate court’s dismissal, rejecting the writ as lacking a clear legal right and duty.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether inmates have a right to parole or to a specific hearing date	Calo/Jolly claim entitlement under former regulation cadence.	No statutory or constitutional entitlement to parole or date; discretion resides with parole authorities.	No right to parole or to a particular date; writ denied.
Whether application of new parole guidelines violated rights	New guidelines deprived them of hearings to which they were entitled.	No liberty interest created by parole statute; changes do not violate rights.	Applying new guidelines does not violate protected liberty interests.
Whether mandamus relief was proper given absence of a clear right/duty	Relators have a clear right to relief through mandamus.	No clear legal right or duty; ordinary remedies exist and are inadequate in this context but not met.	Writ properly denied; relief unavailable on these facts.
Whether the attorney general’s representation should be disqualified	Alleges collusion and impropriety by AG's office.	No evidence supporting disqualification.	Motion to disqualify denied.

State ex rel. Seikbert v. Wilkinson, 69 Ohio St.3d 489 (1994) (parole statute creates no entitlement to parole or process)
Hattie v. Anderson, 68 Ohio St.3d 232 (1994) (due process rights not created by parole statute)
Adkins v. Capots, 46 Ohio St.3d 187 (1989) (parole discretion does not create liberty interest)
State ex rel. Waters v. Spaeth, 131 Ohio St.3d 55 (2012) (clear-right requirement for mandamus relief; clear and convincing standard)
Henderson v. Ohio Dept. of Rehab. & Corr., 81 Ohio St.3d 267 (1998) (no liberty interest in parole; changes not constitutional violation)