State ex rel. Roden v. Ohio Dept. of Rehab. & Corr. (Slip Opinion), 2020 Ohio 408

Petitioner Steven R. Roden, an inmate at Noble Correctional Institution, filed a mandamus petition in the Tenth District (Nov. 2018) seeking aggregation of his prison terms and waiver of filing fees.
The Tenth District referred the case to a magistrate, who recommended sua sponte dismissal for failure to comply with R.C. 2969.25(C)(1) (requiring a cashier-certified statement showing the inmate-account balance for each of the preceding six months).
Roden attached to his petition an affidavit of indigency and a cashier’s statement showing account balance as of a single date, total state pay for six months, and commissary expenditures, but not a month-by-month balance for each of the prior six months.
The court of appeals adopted the magistrate’s recommendation and dismissed the petition; Roden appealed to the Ohio Supreme Court.
The Ohio Supreme Court held Roden did not satisfy the specific statutory requirement, reaffirmed that R.C. 2969.25(C)(1) is mandatory and does not permit substantial compliance, and affirmed dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Roden complied with R.C. 2969.25(C)(1) so his fee-waiver affidavit was adequate	Roden: he submitted an inmate-account statement that substantially complies with the statute	DRC: Roden failed to provide the required cashier-certified month-by-month balances for the preceding six months	Court: Roden failed to comply; statutory requirement is mandatory and substantial compliance is insufficient; dismissal affirmed

State ex rel. Evans v. McGrath, 88 N.E.3d 957 (Ohio 2017) (R.C. 2969.25(C)(1) compliance is mandatory)
State ex rel. White v. Bechtel, 788 N.E.2d 634 (Ohio 2003) (failure to comply with R.C. 2969.25 is grounds for dismissal)
State ex rel. Swain v. Adult Parole Auth., 90 N.E.3d 936 (Ohio 2017) (noncompliance with R.C. 2969.25 is fatal to inmate action)
State ex rel. Neil v. French, 104 N.E.3d 764 (Ohio 2018) (R.C. 2969.25(C) does not permit substantial compliance)
State ex rel. Manns v. Henson, 894 N.E.2d 47 (Ohio 2008) (same—strict compliance required)
State ex rel. Muhammad v. State, 979 N.E.2d 296 (Ohio 2012) (cashier’s statement that did not meet statutory form was insufficient)
Rogers v. Eppinger, 112 N.E.3d 902 (Ohio 2018) (court of appeals properly dismissed petition for failure to attach required inmate-account statement)
Boles v. Knab, 951 N.E.2d 389 (Ohio 2011) (affirming dismissal where affidavit lacked six-month, cashier-certified monthly balances)