State v. Wofford, 2016 Ohio 7188

In 2014 Wofford pled guilty to felonious assault and having weapons under disability; he later moved to withdraw his plea.
The trial court denied withdrawal and imposed an 11-year sentence; Wofford appealed and this court affirmed his convictions and sentence.
Wofford filed additional motions (to void the judgment and for postconviction relief); the trial court denied them and an attempted appeal was dismissed as untimely.
Wofford requested copies of discovery under R.C. 149.43(B)(8); the trial court denied his motion for a judicial finding of a "justiciable claim," concluding no pending proceeding would require the records.
Wofford appealed the denial, arguing the records were necessary to support renewed ineffective-assistance and plea-voluntariness claims; the court held no pending proceeding existed and future claims would be barred by res judicata.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by refusing to find Wofford had a "justiciable claim" under R.C. 149.43(B)(8) and thus denying access to discovery	The State: no abuse — no pending proceeding requires the records and res judicata bars future claims	Wofford: he needs discovery to support claims of ineffective assistance and involuntary plea and had appellate review pending before the Ohio Supreme Court	Court affirmed: no pending justiciable proceeding existed when the motion was filed; speculative or future proceedings insufficient; res judicata bars the asserted claims

State ex rel. Russell v. Thornton, 111 Ohio St.3d 409 (2006) (R.C. 149.43(B)(8) limits incarcerated persons' access to records and requires a sentencing-judge finding of necessity for a justiciable claim)
State ex rel. Fernbach v. Brush, 133 Ohio St.3d 151 (2012) (reinforces requirement that an incarcerated requester obtain a judge's finding that requested criminal-prosecution records are necessary to support a justiciable claim)