State ex rel. Royster v. Brown, 2012 Ohio 2879

Royster filed a Petition for Writ of Mandamus seeking resentencing under HB 86.
The trial court’s judge moved to dismiss the mandamus petition.
HB 86, effective Sept. 30, 2011, states amendments apply prospectively; not retroactive.
Royster’s sentence was imposed before HB 86’s effective date, so not eligible for reduction.
Relator had an adequate remedy at law by appeal for sentencing issues.
The court dismissed the mandamus petition for failure to state a claim; costs to Relator.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether HB 86 applies to reduce an already-imposed sentence	Royster argues HB 86 retroactively reduces sentence.	Brown contends HB 86 not retroactive; applies prospectively.	HB 86 not retroactive; no relief for Royster.
Whether Relator had an adequate remedy by appeal	Royster had no adequate post-judgment remedy to obtain relief otherwise.	Relator could pursue direct appeal and post-judgment motions.	Relator had an adequate remedy at law by appeal.
Whether mandamus is proper relief given available remedies	Relator seeks mandamus to compel resentencing.	Relator’s remedy lies in appeal, not mandamus.	Mandamus not proper; no claim upon which relief may be granted.

State ex rel. Master v. Cleveland, 75 Ohio St.3d 23 (1996) (establishes mandamus relief standards)
State ex rel. Harris v. Rhodes, 5 Ohio St.2d 41 (1966) (mandamus prerequisites and remedy principles)
State ex rel. National City Bank v. Bd. of Education, 520 Ohio St.2d 81 (1988) (statutory interpretation and remedy rules)