State ex rel. Robinson v. LaRose (Slip Opinion)
147 Ohio St. 3d 473
| Ohio | 2016Background
- Jackie Robinson, convicted in 1976–1979 of multiple offenses, has been paroled and reconvicted several times and is currently incarcerated; next parole hearing set for 2017.
- In May 2015 Robinson filed a pro se habeas corpus petition asserting the 1979 trial court lacked jurisdiction because the indictment was not properly signed or file-stamped until 2013.
- The warden moved to dismiss or for summary judgment; the Eleventh District granted the motion and dismissed the petition with prejudice in October 2015.
- The court of appeals found Robinson had an adequate remedy by direct appeal, failed to attach all commitment papers (R.C. 2725.04(D)), and failed to provide a complete affidavit of prior civil actions (R.C. 2969.25(A)).
- The court additionally held habeas is not the proper vehicle to challenge an indictment and that res judicata barred this successive petition because Robinson had raised similar claims in prior habeas filings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can habeas be used to challenge indictment validity? | Robinson: indictment defective, so trial court lacked jurisdiction. | Warden: indictment defects must be raised on direct appeal; habeas inappropriate. | Habeas not appropriate; indictment challenges belong to direct appeal. |
| Did Robinson have an adequate remedy at law? | Robinson pursued habeas instead of appeal. | Warden: direct appeal is an adequate remedy even if not pursued. | Direct appeal is an adequate remedy; habeas unavailable when adequate remedy exists. |
| Is the petition barred by res judicata / successive-petition rules? | Robinson filed previous habeas petitions and repeats claims. | Warden: successive petitions barred; res judicata applies. | Res judicata bars successive habeas petitions; petition dismissed. |
| Were statutory filing requirements met? (commitment papers; R.C. 2969.25 affidavit) | Robinson submitted limited commitment materials and an incomplete affidavit. | Warden: petition defective for failing to attach all commitment papers and incomplete civil-action affidavit. | Petition dismissed for failure to attach all commitment papers and to comply with R.C. 2969.25(A). |
Key Cases Cited
- State ex rel. Arroyo v. Sloan, 142 Ohio St.3d 541 (2015) (habeas is not proper to challenge indictment)
- State ex rel. Hadlock v. McMackin, 61 Ohio St.3d 433 (1991) (sufficiency of indictment must be raised on direct appeal)
- Fugett v. Turner, 140 Ohio St.3d 1 (2014) (failure to attach all commitment papers is fatal)
- Boles v. Knab, 129 Ohio St.3d 222 (2011) (R.C. 2969.25 requirements are mandatory; noncompliance may mandate dismissal)
- Bevins v. Richard, 144 Ohio St.3d 54 (2015) (res judicata bars successive habeas petitions)
- State ex rel. White v. Bechtel, 99 Ohio St.3d 11 (2003) (same: R.C. 2969.25 compliance required)
- State ex rel. McGrath v. McDonnell, 126 Ohio St.3d 511 (2010) (same: procedural requirements for inmate filings enforced)