State v. Henton (Slip Opinion), 146 Ohio St. 3d 9

Henton, pro se, filed a mandamus petition in the Eleventh District Court of Appeals seeking medical records from a county jail.
The court of appeals dismissed the petition for three deficiencies: caption omissions under Civ.R. 10(A); failure to follow form requirements in R.C. 2731.04; and failure to attach an affidavit of prior actions under R.C. 2969.25(A).
R.C. 2969.25(A) requires inmates to file an affidavit describing civil actions filed in the previous five years.
Henton did not attach the required affidavit at any time, despite being a pro se litigant.
The Ohio Supreme Court affirmed the dismissal, holding that compliance with the mandatory affidavit requirement is dispositive and noncompliant petitions are properly dismissed.
The decision relies on prior Ohio authority affirming mandatory nature of the affidavit requirement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal for failure to attach the required affidavit was proper.	Henton contends the petition should not be dismissed on this basis.	State asserts noncompliance with R.C. 2969.25(A) warrants dismissal.	Yes; dismissal affirmed for failure to attach the affidavit.

State ex rel. McGrath v. McDonnell, 126 Ohio St.3d 511 (2010-Ohio-4726) (mandatory affidavit requirement governs inmate actions against government entities)
State ex rel. Leon v. Cuyahoga Cty. Court of Common Pleas, 123 Ohio St.3d 124 (2009-Ohio-4688) (pro se status does not excuse strict compliance)