The State Ex Rel. Martin v. Greene., 2018 Ohio 4201

Andre Martin, an inmate at Southern Ohio Correctional Facility, filed an original mandamus action in the Ohio Supreme Court seeking public records from Larry Greene, the facility's records custodian.
Martin alleges he submitted a public-records request on or about December 15, 2017, and despite follow-up communications never received the requested documents.
Martin requested the Court to compel Greene to produce the records and to award statutory damages.
Greene moved to dismiss, arguing Martin failed to comply with R.C. 2969.25 (inmate filing requirements and affidavits of prior actions/indigency).
The Supreme Court considered whether R.C. 2969.25 applies to original actions filed in the Ohio Supreme Court and set a briefing/evidence schedule after denying the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2969.25’s inmate-filing affidavit/fee-waiver affidavit requirements bar an original mandamus action filed by an inmate in the Ohio Supreme Court	Martin proceeded without attaching the R.C. 2969.25 affidavits and argues for relief on merits (requests production and damages)	Greene contends Martin failed to comply with R.C. 2969.25 and so the complaint must be dismissed	R.C. 2969.25 does not apply to original actions in the Ohio Supreme Court; motion to dismiss denied and alternative writ granted

State ex rel. Perotti v. Clipper, 86 N.E.3d 331 (Ohio 2017) (R.C. 2969.25 requirements are mandatory for applicable inmate civil actions)
State ex rel. McGrath v. McDonnell, 935 N.E.2d 830 (Ohio 2010) (failure to comply with R.C. 2969.25 subjects inmate action to dismissal)
State ex rel. White v. Bechtel, 788 N.E.2d 634 (Ohio 2003) (same)
State ex rel. Sands v. Bunting, 81 N.E.3d 459 (Ohio 2017) (affirming dismissal where R.C. 2969.25 affidavit absent)
State ex rel. Robinson v. LaRose, 67 N.E.3d 765 (Ohio 2016) (same)
State ex rel. Davenport v. State, 54 N.E.3d 1248 (Ohio 2016) (affirming dismissal for failure to file fee-waiver affidavits)