State ex rel. Williams v. Trim (Slip Opinion), 145 Ohio St. 3d 204

Agatha Martin Williams, an inmate, receives a lifetime Timken pension ($412.18/month) deposited into a joint checking account with her adult daughter; funds are periodically transferred into Williams’s prison account.
Williams owes restitution and fines from a criminal sentence; the Department of Rehabilitation and Correction placed a hold on her prison account and transmitted funds to Stark County to satisfy obligations.
Williams exhausted prison grievance procedures and then filed in the court of appeals seeking an injunction, a writ of prohibition, and a writ of mandamus to prevent garnishment and to require the warden to exempt her account as containing pension funds exempt under R.C. 2329.66.
The court of appeals dismissed the entire complaint sua sponte without giving Williams notice or permitting further briefing; Williams appealed to the Ohio Supreme Court.
The Supreme Court affirmed dismissal of the injunctive and prohibitory claims but held that the mandamus claims (challenging attachment of pension-derived funds) could not be dismissed on the merits without notice and further briefing; the case was remanded for briefing and further proceedings on mandamus.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Court of appeals’ power to grant prohibitory injunction	Williams sought injunctive relief to stop garnishment of her inmate account	Warden argued courts lack original jurisdiction for prohibitory injunctions	Dismissal affirmed: court of appeals lacks original jurisdiction to grant prohibitory injunctions
Writ of prohibition against the warden	Williams argued the hold on her account was unauthorized	Warden contended placing a hold is not judicial/quasi-judicial action	Dismissal affirmed: prohibition claim fails because no judicial/quasi-judicial act was alleged
Mandamus to compel exemption of pension-derived funds	Williams argued pension funds remain exempt under R.C. 2329.66 and Daugherty when traceable into her inmate account	Warden argued collection statutes and procedures authorize the hold and that mandamus relief is inappropriate	Dismissal reversed: mandamus claims are colorable and the court must give notice and allow briefing before deciding merits
Sua sponte dismissal without notice	Williams: claims are not frivolous and require adjudication	Appellate court: dismissed whole case based on preliminary briefing	Held partly for Williams: sua sponte dismissal was proper for injunction/prohibition claims but improper as to mandamus claims; remand for briefing on mandamus

State ex rel. Cincinnati Enquirer v. Ronan, 918 N.E.2d 515 (affirming that sua sponte dismissal without notice is limited to frivolous or obviously unprovable claims) (Ohio)
Daugherty v. Cent. Trust Co. of Northeastern Ohio, N.A., 504 N.E.2d 1100 (holding exempt funds retain exempt status in a personal checking account when source is known or traceable) (Ohio)
State ex rel. Crabtree v. Franklin Cty. Bd. of Health, 673 N.E.2d 1281 (holding courts lack original jurisdiction in prohibitory injunctions) (Ohio)
State ex rel. Bell v. Pfeiffer, 961 N.E.2d 181 (setting elements for prohibition) (Ohio)
State ex rel. Bruggeman v. Ingraham, 718 N.E.2d 1285 (defining judicial or quasi-judicial power) (Ohio)
State ex rel. Satow v. Gausse-Milliken, 786 N.E.2d 1289 (mandamus cannot be used to obtain prohibitory relief; court must examine true object of mandamus complaint) (Ohio)