State ex rel. Ware v. Walsh (Slip Opinion), 2020 Ohio 769

In March 2019, inmate Kimani Ware filed a mandamus complaint in the Ninth District Court of Appeals alleging Summit County Prosecutor Sherri Bevan Walsh failed to properly respond to a public-records request.
R.C. 2969.25(A) requires an inmate suing a government employee in a court of appeals to file an affidavit describing each civil action or appeal the inmate filed in the previous five years, including the outcome per R.C. 2969.25(A)(4).
Ware submitted an affidavit listing six civil actions and providing the information required by subsections (A)(1)–(3).
The Ninth District found Ware did not comply with R.C. 2969.25(A)(4) because his affidavit did not describe the outcomes of those prior actions beyond stating they were not found frivolous.
The Ninth District dismissed Ware’s petition for failure to strictly comply with R.C. 2969.25(A); Ware appealed to the Ohio Supreme Court.
The Supreme Court affirmed, holding strict compliance with R.C. 2969.25(A) is mandatory and failure to comply requires dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ware complied with R.C. 2969.25(A)(4) by listing prior actions and stating none were deemed frivolous	Ware argued his affidavit sufficiently listed prior actions and stated they were not deemed frivolous	Walsh argued the affidavit failed to describe the outcomes of the prior actions as required by (A)(4)	Court held Ware did not comply with (A)(4); strict compliance is required and dismissal was proper

State ex rel. Swanson v. Ohio Dept. of Rehab. & Corr., 156 Ohio St.3d 408 (reiterating that R.C. 2969.25 requires strict compliance)
State ex rel. Hall v. Mohr, 140 Ohio St.3d 297 (holding failure to comply with R.C. 2969.25 requires dismissal)