State v. Battigaglia, 2021 Ohio 2758

Romero A. Battigaglia filed motions (July 21, 2020) to vacate costs and fines and lift bench warrants in two 2009 Canton cases (2009 TRC 07560 and 2009 CRB 04667).
The Canton Municipal Court denied the motions on September 8, 2020.
Battigaglia appealed both denials on November 5, 2020; the cases were later consolidated.
On April 30, 2021, the trial court reduced the fines and costs to a civil judgment and cancelled the bench warrant.
The State moved to dismiss the appeal as moot; the Fifth District agreed and dismissed the appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying Battigaglia’s motion to vacate costs and fines without determining if the amounts were due and uncollectible	The State: appeal is moot because the trial court later reduced the fines to a civil judgment and cancelled the bench warrant, providing the relief sought	Battigaglia: court erred by not first determining whether the fines/costs were due or uncollectible before denying the motion	The court dismissed the appeal as moot because the trial court later afforded the relief requested (fines reduced; warrant cancelled), so no live controversy remained

United States v. Alaska S.S. Co., 253 U.S. 113 (1920) (federal courts may not decide moot or abstract questions)
California v. San Pablo & Tulare R. Co., 149 U.S. 308 (1893) (federal courts should not answer moot questions)
North Carolina v. Rice, 404 U.S. 244 (1971) (reiterating that courts lack power to decide moot controversies)
Fortner v. Thomas, 22 Ohio St.2d 13 (1970) (Ohio courts exercise restraint in non-justiciable controversies)
Miner v. Witt, 82 Ohio St. 237 (1910) (when an event renders relief impossible, courts dismiss the error proceeding)
Tschantz v. Ferguson, 57 Ohio St.3d 131 (1991) (dismissing actions rendered moot by subsequent events)