Ohio Case Commentaries

Official Release and Oath Administration for the July 2025 Ohio Bar Examination: Non‑Precedential Administrative Action of the Supreme Court of Ohio

Date: Oct 30, 2025

Official Release and Oath Administration for the July 2025 Ohio Bar Examination: Non‑Precedential Administrative Action of the Supreme Court of Ohio Introduction In 2025-Ohio-4877 (Administrative...

Parisi Left Intact for Now: Mandamus Dismissed Without Opinion While Chief Justice Kennedy Calls to Restore Public Records Act Control Over Court Records and Apply H.B. 265’s Affirmation Requirement

Date: Oct 24, 2025

Parisi Left Intact for Now: Mandamus Dismissed Without Opinion While Chief Justice Kennedy Calls to Restore Public Records Act Control Over Court Records and Apply H.B. 265’s Affirmation Requirement...

Enhanced Actual Suspension for Violent Threats Absent Mental-Health Mitigation: Ohio Supreme Court Clarifies Sanctioning in Attorney Discipline

Date: Oct 24, 2025

Enhanced Actual Suspension for Violent Threats Absent Mental-Health Mitigation: Ohio Supreme Court Clarifies Sanctioning in Attorney Discipline Introduction In Disciplinary Counsel v. Taylor, Slip...

Clarifying “Additional Defendants” in Ohio Medical-Claim Actions: No Civ.R. 15(D) Compliance Needed and 180-Day Extension Not Limited to Newly Discovered Parties (Lewis v. MedCentral Health Sys.)

Date: Oct 24, 2025

Clarifying “Additional Defendants” in Ohio Medical-Claim Actions: No Civ.R. 15(D) Compliance Needed and 180-Day Extension Not Limited to Newly Discovered Parties Case: Lewis v. MedCentral Health...

Strict, Contemporaneous Compliance with R.C. 2969.25(A) Is Required; Noncompliance Requires Dismissal Without Prejudice and Cannot Be Cured by Later Amendment

Date: Oct 24, 2025

Strict, Contemporaneous Compliance with R.C. 2969.25(A) Is Required; Noncompliance Requires Dismissal Without Prejudice and Cannot Be Cured by Later Amendment Introduction In State ex rel. Mason v....

Rigorous Gatekeeping of Extraordinary Writs and the Court’s Use of Alternative Writs under S.Ct.Prac.R. 12.04 and 12.05: Analysis of the Supreme Court of Ohio’s October 22, 2025 Case Announcements

Date: Oct 24, 2025

Rigorous Gatekeeping of Extraordinary Writs and the Court’s Use of Alternative Writs under S.Ct.Prac.R. 12.04 and 12.05: Analysis of the Supreme Court of Ohio’s October 22, 2025 Case Announcements...

Only the Office of Disciplinary Counsel May Invoke Reciprocal Discipline in Ohio; Court Flags Risks of Mandatory Reciprocity During Pending Ohio Appeals

Date: Oct 24, 2025

Only the Office of Disciplinary Counsel May Invoke Reciprocal Discipline in Ohio; Court Flags Risks of Mandatory Reciprocity During Pending Ohio Appeals Introduction In 10/22/2025 Case Announcements...

Whole-Record Review of Juror Bias Permits Reliance on Group Voir Dire Responses: State v. Rogers (2025-Ohio-4794)

Date: Oct 24, 2025

Whole-Record Review of Juror Bias Permits Reliance on Group Voir Dire Responses Commentary on State v. Rogers, 2025-Ohio-4794 (Supreme Court of Ohio) Introduction In State v. Rogers, the Supreme...

Prospective Application of Amended S.Ct.Prac.R. 4.03(A) and Strict Limits on Habeas Relief Reaffirmed: Gordon v. Smith

Date: Oct 22, 2025

Prospective Application of Amended S.Ct.Prac.R. 4.03(A) and Strict Limits on Habeas Relief Reaffirmed: Gordon v. Smith Introduction In Gordon v. Smith, 2025-Ohio-4768, the Supreme Court of Ohio...

Strict, Time-of-Filing Compliance with R.C. 2969.25(A): No Post-Filing Cure via Updated Affidavits or Civ.R. 15 in State ex rel. Harris v. Schwendeman

Date: Oct 22, 2025

Strict, Time-of-Filing Compliance with R.C. 2969.25(A): No Post-Filing Cure via Updated Affidavits or Civ.R. 15 Introduction In State ex rel. Harris v. Schwendeman, Slip Opinion No. 2025-Ohio-4769,...

Explicit Pleading Required: Generic "Failure to State a Claim" Does Not Preserve R.C. 2744 Political-Subdivision Immunity; Late Amendments May Be Denied for Unjustified, Prejudicial Delay

Date: Oct 18, 2025

Explicit Pleading Required: Generic "Failure to State a Claim" Does Not Preserve R.C. 2744 Political-Subdivision Immunity; Late Amendments May Be Denied for Unjustified, Prejudicial Delay...

Finality Is Factual, Not Legal: Ohio Supreme Court Ends Deference to Industrial Commission’s Legal Interpretations of VSSR Rules and Clarifies “Other Heavy Objects” Under Adm.Code 4123:1-3-13(E)(7)

Date: Oct 18, 2025

Finality Is Factual, Not Legal: Ohio Supreme Court Ends Deference to Industrial Commission’s Legal Interpretations of VSSR Rules and Clarifies “Other Heavy Objects” Under Adm.Code 4123:1-3-13(E)(7)...

Ohio Supreme Court Caps Clerk Technology Fee at $1 Total Per Service for “Complete Record” Charges, Not Per Page

Date: Oct 17, 2025

Ohio Supreme Court Caps Clerk Technology Fee at $1 Total Per Service for “Complete Record” Charges, Not Per Page Case: State ex rel. Gault v. Medina County Court of Common Pleas Clerk, Slip Opinion...

Timeliness Is for the Arbitrator: Ohio Supreme Court Bars Employer Self‑Help on Arbitration Deadlines and Requires SERB to Explain ULP Dismissals

Date: Oct 17, 2025

Timeliness Is for the Arbitrator: Ohio Supreme Court Bars Employer Self‑Help on Arbitration Deadlines and Requires SERB to Explain ULP Dismissals Introduction In State ex rel. Staple v. State...

No duty to convert or supply proprietary software for cellphone extractions under Ohio’s Public Records Act: State ex rel. Castellon v. Maloney

Date: Oct 16, 2025

No duty to convert or supply proprietary software for cellphone extractions under Ohio’s Public Records Act Commentary on State ex rel. Castellon v. Maloney, Slip Opinion No. 2025-Ohio-4687 (Supreme...

Snodgrass v. Trumbull Corr. Inst.: Conclusory Affidavits Cannot Sustain Law‑Enforcement or Security Exemptions—Prison Device and Disciplinary Records Are Disclosable Absent Specific Proof

Date: Oct 16, 2025

Snodgrass v. Trumbull Corr. Inst.: Conclusory Affidavits Cannot Sustain Law‑Enforcement or Security Exemptions—Prison Device and Disciplinary Records Are Disclosable Absent Specific Proof...

Visiting-Judge Assignment Irregularities Render Judgments Voidable, Not Void: Ohio Supreme Court Reaffirms Limits of Habeas in Lowe v. Smith

Date: Oct 9, 2025

Visiting-Judge Assignment Irregularities Render Judgments Voidable, Not Void: Ohio Supreme Court Reaffirms Limits of Habeas in Lowe v. Smith Case: Lowe v. Smith, Warden, Slip Opinion No....

Commutation Is Not a New Judgment: Ohio Supreme Court Confirms Governor’s Power to Substitute LWOP for Death Without Ex Post Facto Implications

Date: Oct 9, 2025

Commutation Is Not a New Judgment: Ohio Supreme Court Confirms Governor’s Power to Substitute LWOP for Death Without Ex Post Facto Implications Case: State ex rel. Hawkins v. Frederick, Slip Opinion...

Pleading Matters in Election Mandamus: Generic “Any Other Relief” Is Insufficient to Compel an R.C. 3503.24(B) Hearing or Alternative Remedies

Date: Oct 9, 2025

Pleading Matters in Election Mandamus: Generic “Any Other Relief” Is Insufficient to Compel an R.C. 3503.24(B) Hearing or Alternative Remedies Introduction In State ex rel. Hicks v. Adams County...

No Prohibition for Procedural Missteps Under R.C. 2981.03: Subject-Matter Jurisdiction vs. Exercise of Jurisdiction in Post-Sentence Property-Return Orders

Date: Oct 9, 2025

No Prohibition for Procedural Missteps Under R.C. 2981.03: Subject-Matter Jurisdiction vs. Exercise of Jurisdiction in Post-Sentence Property-Return Orders Introduction This commentary analyzes the...