State v. Taylor, 2021 Ohio 758

Michael Taylor was convicted by jury of two counts of aggravated murder (with firearm specifications) and sentenced to consecutive life terms without parole plus mandatory firearm terms.
This court affirmed Taylor’s convictions on direct appeal in 2016.
In 2019–2020 Taylor (pro se) sought a copy of his presentence investigation (PSI) from the trial court and filed an application for a writ of mandamus directing a trial judge to mail him the PSI.
The state opposed mandamus, arguing the trial court cannot issue a writ to itself under R.C. 2731.01; the trial court denied mandamus and dismissed the production request as moot or nonfinal on appeal.
The trial court also noted it has no duty to disclose the PSI; R.C. 2951.03(D)(3) requires the PSI be retained under seal.
On accelerated appeal, the Sixth District affirmed, holding mandamus unavailable because a court cannot compel itself to act and there is no legal duty to provide the sealed PSI.

Issue	Plaintiff's Argument (Taylor)	Defendant's Argument (State/Trial Ct.)	Held
Whether the trial court unconstitutionally denied Taylor access to his PSI by refusing to mail it and by denying mandamus	Taylor argued he had a right to obtain the PSI to support appellate claims and sought mandamus compelling the trial judge to mail it	The state argued the trial court cannot issue a writ to itself and there is no duty to mail a PSI; the PSI is sealed by statute	Mandamus denied: a court cannot compel itself to act and the trial court has no duty to provide the PSI
Whether alleged prosecutorial misconduct (improper impeachment tactics) denied due process and warranted relief	Taylor claimed prosecutorial tactics violated his right to a fair trial and relied on the PSI to pursue this claim	The state asserted the mandamus vehicle was improper to obtain the PSI and the court need not address the substantive trial complaint in mandamus proceedings	Court did not reach the merits of the misconduct claim; relief denied because mandamus unavailable
Whether a state rule precluding pro se access to sentencing evidence (PSI) is unconstitutional	Taylor contended it is unconstitutional to deny a pro se defendant access to sentencing evidence relied on by the court	The state/trial court maintained PSI disclosure is governed by statute requiring sealing; no duty to disclose even to pro se defendants	Held against Taylor: statutory seal controls; no mandamus remedy to compel disclosure

State ex rel. Brown v. Nusbaum, 95 N.E.3d 365 (Ohio 2017) (de novo review standard for mandamus dismissal)
State ex rel. Zander v. Judge of Summit Cty. Common Pleas Court, 129 N.E.3d 401 (Ohio 2019) (complaint dismissal when no set of facts would warrant relief)
State ex rel. Love v. O’Donnell, 81 N.E.3d 1250 (Ohio 2017) (mandamus elements: clear right, clear duty, no adequate remedy at law)
State ex rel. Russell v. Klatt, 150 N.E.3d 943 (Ohio 2020) (mandamus will not compel a court to order itself to act)