IN THE COURT OF APPEALS OF OHIO
TENTH APPELLATE DISTRICT
James K. Bishop, :
Plaintiff-Appellant, :
No. 25AP-671
v. : (Ct. of Cl. No. 2025-00495JD)
Ohio Department of : (REGULAR CALENDAR) Rehabilitation and Correction, :
Defendant-Appellee.
:
D E C I S I O N
Rendered on August 27, 2026
On brief: James K. Bishop, pro se.
On brief: [Andy Wilson], Attorney General, Lindsey M. Grant, and Camryn E. Hughes, for appellee.
APPEAL from the Court of Claims of Ohio
DORRIAN, J.
{¶ 1} Plaintiff-appellant, James K. Bishop, appeals pro se from an order of the Court of Claims of Ohio granting a partial motion to dismiss and a motion to transfer to the administrative docket filed by defendant-appellee, Ohio Department of Rehabilitation and Correction (“ODRC”). For the following reasons, we reverse in part and remand. I. Facts and Procedural History
{¶ 2} Bishop is confined at Noble Correctional Institution. On May 16, 2025, Bishop filed a pro se complaint in the Court of Claims of Ohio asserting claims against the director of ODRC and the warden and other employees of Noble Correctional Institution for negligence, malicious prosecution, and abuse of process. Bishop alleged he was placed in segregation on two occasions in March 2025 for violating institutional rules. Bishop
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claimed the conduct reports filed against him for violating institutional rules were unjustified and malicious. Bishop asserted that while he was in segregation certain items of his property were lost or stolen due to negligence of the corrections officers. Bishop sought compensatory damages of $217,228.09, punitive damages, reversal and removal of the conduct reports that resulted in placement in segregation, a declaration that certain prison regulations were unconstitutional, an injunction prohibiting enforcement of those regulations, and attorney fees and costs. Bishop attached to his complaint an itemized list of the allegedly lost or stolen property. As relevant to this appeal, the list included six photographs that were indicated as being irreplaceable. Bishop placed a total value of $217,000 on the six photographs, itemized as $17,000 for one photograph of his girlfriend, $100,000 for two photographs of Bishop with his deceased brother, and $100,000 for three photographs of Bishop with his grandchildren. Along with his complaint, Bishop moved for appointment of counsel.
{¶ 3} On June 20, 2025, ODRC filed a partial motion to dismiss, arguing that Bishop’s malicious prosecution and abuse of process claims were based on decisions of the Rules Infraction Board and that the Court of Claims lacked jurisdiction over such decisions. ODRC asserted it was entitled to immunity for any claims arising from alleged violations of its internal policies or procedures. ODRC also argued the Court of Claims lacked jurisdiction over any claims for violations of Bishop’s constitutional rights.
{¶ 4} Also on June 20, 2025, ODRC moved to transfer Bishop’s negligence claims related to his lost or stolen property to the court’s administrative docket, asserting that the total value of the alleged lost property was less than the threshold amount set forth in R.C. 2743.10. Bishop filed a memorandum in opposition to the motion to transfer, arguing that his lost photographs had a value of hundreds of thousands of dollars if sold to a magazine or millions of dollars if sold as artwork. Bishop further argued that the photographs with his deceased brother were the only existing copies and therefore could not be assessed based on market value because they were irreplaceable.
{¶ 5} On June 23, 2025, Bishop filed a motion for default judgment, alleging that as of June 18, 2025, ODRC had failed to defend or otherwise appear in the action.
{¶ 6} The Court of Claims issued an order on July 25, 2025, addressing the pending motions. The court denied Bishop’s motion for appointment of counsel, concluding he was
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not entitled to appointed counsel because he filed a civil claim seeking monetary damages and had not alleged a threat by the state to take his life, liberty, or property. The court also denied Bishop’s motion for default judgment, concluding that ODRC had timely filed its motion to dismiss and motion to transfer based on the date of service of the complaint and the existence of a legal holiday during the time for ODRC’s response. The court granted ODRC’s partial motion to dismiss, ruling that it lacked subject-matter jurisdiction over claims related to the decision to place Bishop in segregation or violations of Bishop’s constitutional rights. The court further concluded ODRC was entitled to discretionary immunity for claims challenging the internal policies and procedures that resulted in Bishop being sent to segregation.
{¶ 7} The court also granted ODRC’s motion to transfer Bishop’s negligence claims to the court’s administrative docket. The court acknowledged Bishop’s assertion that the six lost photographs had a total value to him of $217,000 but concluded he failed to demonstrate exceptional circumstances that warranted departing from the standard of market value as the measure of property loss. The court asserted that it would not speculate as to the specific market value of the lost photographs but held that “accepting the allegations of the Complaint as true, the total amount in controversy for the alleged loss of personal property cannot be more than $10,000, as a matter of law.”1 (July 25, 2025 Entry at 8-9.) Based on its conclusion that Bishop’s damages could not exceed $10,000, the court transferred Bishop’s negligence claims to the court’s administrative docket. II. Assignments of Error
{¶ 8} Bishop appeals and assigns the following three assignments of error for our review:
1 The court’s references to accepting the allegations of the complaint as true and reaching a conclusion as a
matter of law suggest the court may have been borrowing elements from the standards applicable to other types of motions to create a hybrid test for granting a motion to transfer. For example, when assessing a motion to dismiss under Civ.R. 12(B)(6) for failure to state a claim upon which relief can be granted, a court must accept all factual allegations of a complaint as true and draw all reasonable inferences in favor of the non-moving party. See Mobley v. Supreme Court of Ohio, 2021-Ohio-391, ¶ 8 (10th Dist.). When considering whether to grant a motion for summary judgment under Civ.R. 56, a court must determine whether the moving party is entitled to judgment as a matter of law. See Hernandez v. Ohio Dept. of Rehab. & Corr., 2017- Ohio-8646, ¶ 12 (10th Dist.). Yet, ODRC did not file a motion to dismiss or a motion for summary judgment. Rather, ODRC filed a motion to transfer, and our analysis focuses on a motion to transfer alone. Our analysis and conclusion does not, however, prohibit the Court of Claims from considering, pursuant to Civ.R. 12 and 56 and any other applicable Civil Rule, motions to dismiss and motions for summary judgment.
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[I.] THE TRIAL COURT ABUSED ITS DISCRETION, BY FALSELY CLAIMING THAT “THE LOSS OF PHOTOGRAPHS WITH FAMILY MEMBERS IS INHERENTLY SENTIMENTAL.
[II.] THE TRIAL COURT ABUSED ITS DISCRETION WHEN IT TRANSFERRED THIS ACTION FOR ADMINISTRATIVE REVIEW, CLAIMING THAT THE FAIR MARKET VALUE IS LESS THAN $10,000.00. EACH VIOLATED DUE PROCESS OF LAW AND THE LACK OF PROPER VENUE DEPRIVED THE CLERK OF JURISDICTION OVER THE MATTER AND MADE THE JUDGMENT VOID.
[III.] “WHETHER; THE TRIAL COURT ERRED AS A MATTER OF LAW AND ABUSED ITS DISCRETION IN IGNORING THE CIVIL RULES AND OHIO STATUTES BY PURPORTING TO SET THIS CASE FOR AN ADMINISTRATIVE REVIEW. EACH VIOLATED DUE PROCESS OF LAW AND THE LACK OF PROPER VENUE DEPRIVES THE CLERK OF JURISDICTION OVER THE MATTER AND MADE THE JUDGMENT VOID.
(Sic passim.) III. Discussion
{¶ 9} Bishop’s appeal only challenges the portion of the court’s July 25, 2025 order granting ODRC’s motion to transfer his negligence claims to the court’s administrative docket. Therefore, we limit our review to that portion of the order.
A. ODRC’s jurisdictional argument
{¶ 10} Before addressing the merits of Bishop’s assignments of error, we must consider ODRC’s assertion that this court lacks jurisdiction over the appeal because the order granting the motion to transfer Bishop’s negligence claims to the administrative docket is not a final, appealable order.
{¶ 11} Courts of appeals have jurisdiction to review final orders of lower courts.
Ohio Const., art. IV, § 3(B)(2). “A trial court order is final and appealable if it meets the requirements of R.C. 2505.02 and, if applicable, Civ.R. 54(B).” Jack Maxton Chevrolet, Inc. v. Hanbali, 2016-Ohio-1244, ¶ 6 (10th Dist.). See State ex rel. Sands v. Culotta, 2021-Ohio-1137, ¶ 7 (“A court’s order is final and appealable if the requirements of R.C. 2505.02 are met.”). R.C. 2505.02(B) sets forth the types of orders that constitute final orders. One type of final order is “[a]n order that affects a substantial right in an action that
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in effect determines the action and prevents a judgment.” R.C. 2505.02(B)(1). Another type of final order is “[a]n order that affects a substantial right made in a special proceeding.” R.C. 2505.02(B)(2).
{¶ 12} ODRC asserts the transfer order did not address the merits of Bishop’s negligence claims and therefore did not determine the action and prevent Bishop from obtaining judgment. Thus, ODRC argues that the order transferring Bishop’s claims to the administrative docket is not a final order under R.C. 2505.02(B)(1). This court previously has granted motions to dismiss for lack of jurisdiction on that basis in similar appeals from orders transferring claims to the administrative docket of the Court of Claims. See Bruggeman v. Ohio Dept. of Rehab. & Corr., 2021-Ohio-926, ¶ 12 (10th Dist.); Woods v. Ohio Dept. of Rehab. & Corr., 2017-Ohio-1022, ¶ 11 (10th Dist.). However, in those decisions the court focused only on whether the order was final under R.C. 2505.02(B)(1) because it effectively determined the action and prevented a judgment but did not analyze whether the transfer order was a final order as defined by R.C. 2505.02(B)(2). See Bruggeman at ¶ 10; Woods at ¶ 9. Therefore, we are not bound by those decisions when determining whether the order in this case is a final order under R.C. 2505.02(B)(2).
{¶ 13} A “substantial right” is defined as “a right that the United States Constitution, the Ohio Constitution, a statute, the common law, or a rule of procedure entitles a person to enforce or protect.” R.C. 2505.02(A)(1). An order affects a substantial right for purposes of R.C. 2505.02(B)(2) if immediate appeal is necessary to effectively protect the right. Wilhelm-Kissinger v. Kissinger, 2011-Ohio-2317, ¶ 7. See Frash v. Ohio Dept. of Rehab. & Corr., 2013-Ohio-2783, ¶ 13 (10th Dist.) (“[A] trial court order that does not deprive a party of the opportunity for meaningful review by way of appeal following final judgment does not affect a substantial right and is thus not appealable pursuant to R.C. 2505.02(B)(2).”). In this case, the trial court’s order affects Bishop’s right to recover damages on his negligence claims, limiting his recovery to $10,000 or less, notwithstanding Bishop’s assertion that his damages exceeded $200,000. See McConnell v. Sexton, 2022-Ohio- 1894, ¶ 9 (12th Dist.) (“The trial court’s summary-judgment order here affects McConnell’s right to recover certain damages for negligence—a substantial right.”). Additionally, as explained below, if the order is not immediately appealed, any damages awarded to Bishop in an administrative determination would only be subject to review by the Court of Claims
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and could not be further appealed. R.C. 2743.10(D). Therefore, we conclude that the court’s order granting the motion to transfer affected a substantial right.
{¶ 14} For purposes of the final order statute, a “special proceeding” is defined as “an action or proceeding that is specially created by statute and that prior to 1853 was not denoted as an action at law or a suit in equity.” R.C. 2505.02(A)(2). This court has concluded that actions against the state in the Court of Claims constitute special proceedings because “ ‘[p]rior to the enactment of R.C. Chapter 2743, actions against the state of Ohio were barred by the doctrine of sovereign immunity.’ ” Frash at ¶ 13, quoting Taylor v. Ohio State Univ., 1995 Ohio App. LEXIS 1910, *4 (10th Dist. May 11, 1995). Other appellate courts have reached the same conclusion. See Adams v. Cox, 2008-Ohio-719, ¶ 6 (4th Dist.) (“Because the state had immunity at common law and suits against it were not originally recognized, we believe proceedings under R.C. Chapter 2743 amount to special proceedings.”).
{¶ 15} Accordingly, we conclude that the order in this case transferring Bishop’s claims to the administrative docket is a final order under R.C. 2505.02(B)(2) because it affected a substantial right and was made in a special proceeding.
{¶ 16} Having concluded that the transfer order is a final order under R.C. 2505.02(B)(2), we next consider whether Civ.R. 54(B) applies.2 Civ.R. 54(B) provides in relevant part that “[w]hen more than one claim for relief is presented in an action . . . the court may enter final judgment as to one or more but fewer than all of the claims . . . only upon an express determination that there is no just reason for delay.” For purposes of Civ.R. 54, a judgment is defined as a “written entry ordering or declining to order a form of relief, signed by a judge, and journalized on the docket.” Civ.R. 54(A). As noted above, Civ.R. 54(B) applies when a court “enter[s] final judgment as to one or more but fewer than
2 Some courts have suggested that Civ.R. 54(B) may not apply to orders affecting substantial rights in special
proceedings. See Monroeville v. Gray Matter Advisors, Inc., 2026-Ohio-2110, ¶ 59 (6th Dist.) (“While there is mixed authority regarding the need for Civ.R. 54(B) language for a final order under R.C. 2505.02(B)(2), we have noted most jurisdictions require Civ.R. 54(B) language and followed suit.”); Caddyshack, L.L.C. v. Ahner, 2024-Ohio-4609, ¶ 26 (6th Dist.) (“Notwithstanding the debate about whether Civ.R. 54(B) should apply to final orders in special proceedings under R.C. 2505.02(B)(2), the majority of the caselaw suggests that it does.”); State v. West, 2021-Ohio-4682, ¶ 27 (2d Dist.) (“Some courts have questioned whether [Civ.R. 54(B) language] should be required for orders affecting substantial rights in special proceedings.”); Garden v. Langermeier, 2017-Ohio-972, ¶ 13, fn. 1 (8th Dist.) (asserting that Civ.R. 54(B) “undoubtedly” applies to final orders under R.C. 2505.02(B)(1) but that it is less clear whether it applies to final orders under R.C. 2505.02(B)(2)). We need not address this question, however, based on our conclusion that Civ.R. 54(B) does not apply in this case because the trial court’s order entered judgment on all of Bishop’s claims.
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all of the claims or parties.” (Emphasis added.) In this case, Civ.R. 54(B) does not apply to the trial court’s July 25, 2025 order, because the court entered judgment as to all of Bishop’s claims by ordering the forms of relief that ODRC requested—i.e., dismissal of the claims that were not based in negligence and transfer to the administrative docket of the claims that were based in negligence. See Miller v. First Internatl. Fid. & Trust Bldg., 2007-Ohio- 2457, ¶ 10 (holding that Civ.R. 54(B) language was not required in a case where the trial court entered judgment on all claims and against all parties).
{¶ 17} Because we conclude that the trial court’s order is a final order under R.C. 2505.02(B)(2) and that Civ.R. 54(B) does not apply, the order is a final, appealable order. Therefore, we reject ODRC’s argument that this court lacks jurisdiction over the present appeal.
B. Authority of Court of Claims to transfer case to administrative docket
{¶ 18} Bishop’s second and third assignments of error assert that ODRC erred by transferring his negligence claims to the court’s administrative docket. We will address these assignments of error together because they both challenge the transfer to the administrative docket.
{¶ 19} The Court of Claims is a statutorily created court and its jurisdiction “is limited by statute and specifically confined to the powers conferred by the legislature.” State ex rel. DeWine v. Court of Claims of Ohio, 2011-Ohio-5283, ¶ 21. The court’s order in this case granting ODRC’s motion to transfer cited R.C. 2743.10(A), which provides that, with limited exceptions, “[c]ivil actions against the state for ten thousand dollars or less shall be determined administratively by the clerk of the court of claims.” The court’s order emphasized the word “shall” in R.C. 2743.10(A), suggesting that the court was required to transfer any complaint seeking $10,000 or less to the administrative docket for determination by the clerk of courts. However, a more complete reading of R.C. 2743.10 indicates that administrative determination of claims by the clerk of courts applies when a claimant selects that method of resolution and expressly seeks to recover $10,000 or less on a claim, not when, as in this case, a claimant files a complaint seeking damages of more than $10,000.
{¶ 20} It is a fundamental principle that courts must give effect to every part of a statute. See, e.g., State ex rel. Carna v. Teays Valley Local School Dist. Bd. of Edn., 2012-
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Ohio-1484, ¶ 18 (“[W]e must accord significance and effect to every word, phrase, sentence, and part of the statute[.]”); Wachendorf v. Shaver, 149 Ohio St. 231 (1948), paragraph five of the syllabus (holding that “significance and effect should, if possible, be accorded to every word, phrase, sentence and part of an act”); State v. Barbee, 45 Ohio St. 347, 350 (1887) (“It is a fundamental rule that to properly determine the effect to be given any clause of an instrument, a due regard must be had to all its parts, and its various provisions be so construed, if possible, as to make a harmonious whole.”). Therefore, the requirement under R.C. 2743.10(A) that civil actions of $10,000 or less “shall be determined administratively by the clerk of the court of claims” must be considered within the context of the entire statute. The next subsection of R.C. 2743.10 provides that civil actions covered by R.C. 2743.10(A), i.e., civil actions against the state for $10,000 or less, “shall be commenced by filing with the clerk on complaint forms prescribed by the supreme court.” R.C. 2743.10(B). That filing triggers a process in which the clerk sends copies of the form complaint to the relevant state entity, which then investigates the allegations of the complaint and reports the findings of its investigation to the clerk of courts. Id. The clerk forwards a copy of the investigation report to the claimant, who may respond in writing or by appearing before the clerk. Id. The clerk then determines the civil action and makes a report of the decision, including findings of fact and conclusions of law. R.C. 2743.10(C). The statute expressly provides that the rules of evidence shall not apply in the determination and that “[p]rocedures shall be governed by rules promulgated by the clerk, shall be informal, and shall be designed to accommodate persons who are not skilled in the law.” Id. Upon motion of a party, the clerk’s determination is subject to review by the Court of Claims, but no further appeal of the judgment is permitted. R.C. 2743.10(D). These statutory provisions are mirrored in the local rules of the Court of Claims. See L.C.C.R. 7.
{¶ 21} Thus, when read together as a whole, the provisions of R.C. 2743.10 effectively create a “small claims” process within the Court of Claims, that individuals who seek $10,000 or less from the state can invoke by filing their claim on the appropriate form. The statute expressly provides that such process must be governed by rules “designed to accommodate persons who are not skilled in the law.” R.C. 2743.10(C). By invoking the administrative determination process, the claimant loses the opportunity to have his claim
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adjudicated in the first instance by a judge of the Court of Claims but also avoids some of the burdens associated with full-scale litigation.
{¶ 22} This reading of R.C. 2743.10 is consistent with the history of the statute. As originally enacted, the statute provided that claims of less than $100 were to be determined administratively by the clerk of courts, and that claims of more than $100 but less than $1,000 could be determined administratively by written consent of the claimant. Am.Sub.H.B. No. 800, 135 Ohio Laws, Part II, 869, 875-76. The “by written consent” provision was removed in 1978, and the law was amended to provide that all claims of $1,000 or less were to be determined administratively by the clerk of courts. Am.Sub.H.B. No. 149, 137 Ohio Laws, Part I, 1950, 1954-55. The General Assembly increased threshold for administrative determination to $2,500 or less in 1989 and then again to $10,000 or less in 2012. Am.Sub.H.B. No. 111, 143 Ohio Laws, Part II, 2330, 2416-17; 2012 Am.Sub.H.B. No. 487. Although the threshold amount for administrative determination has been increased, the main elements of the administrative determination process have remained the same since the Court of Claims was created.
{¶ 23} Moreover, the context in which R.C. 2743.10 was enacted also supports this reading of the statute. Prior to creation of the Court of Claims, an individual with a claim against the state could seek redress by presenting the claim to the Ohio Sundry Claims Board. See Kahle & Schmidt, Claims Against the State of Ohio: Sovereign Immunity, the Sundry Claims Board and the Proposed Court of Claims Act, 35 Ohio St.L.J. 462, 472 (1974). That entity was composed of the state auditor, the attorney general, the chairperson of the finance committee of the Ohio House of Representatives, the chairperson of the finance committee of the Ohio Senate, and the director of the state office of budget and management. Id. The Sundry Claims Board’s procedure was described in an article written shortly before the Court of Claims was created:
The [Sundry Claims] Board is empowered to receive “papers representing claims again [sic] the state.” Presently the Board implements this provision by receiving claims on a special form, forwarding one copy of the claim to the state agency involved, and requesting that the “defendant” agency investigate the claim and submit a report to the Board. After receiving the report, the Board forwards a copy of it to the claimant and schedules the claim for a hearing. In claims under $1,000, unless the claimant requests otherwise, the hearing is
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restricted to a private consideration based on the forms alone, with no witnesses testifying and no additional evidence taken. A full adversary hearing is held on claims over $1,000. . . .
There are no rules of pleading as such. The Board requires only that the claim be submitted on a special form and that the statement of the claim be specific enough for the Board to determine what the alleged wrong is and which state agency is involved. All claims are returned to the claimant by the Board until these minimal requirements are met.
(Footnotes omitted.) Id. at 475-76. Claims of $1,000 or less that were approved by the Sundry Claims Board could be paid automatically, while claims of more than $1,000 required legislative approval through an annual sundry claims appropriations bill. Id. at 480.
{¶ 24} It is clear that many elements of the Sundry Claims Board’s procedure were replicated in R.C. 2743.10 for small claims against the state in the Court of Claims, including requiring the claim to be filed on a particular form, requiring the agency or entity that is the subject of the claim to investigate and respond, and utilizing informal procedures for presenting the claim. Thus, it appears the General Assembly intended to retain crucial aspects of the Sundry Claims Board process for small claims in the Court of Claims. It is notable that claims of more than $1,000 required a full hearing of the Sundry Claims Board. That threshold was preserved in the original Court of Claims Act, which provided for claims of less than $100 to be determined administratively by the clerk of courts, and claims of more than $100 but less than $1,000 to be determined administratively by the clerk by written consent of the claimant. The threshold amount for administrative determination of claims has been increased since the Court of Claims was created, but the core principle remains—a less formal method for resolving small claims against the state.
{¶ 25} There is no provision of R.C. 2743.10 authorizing the Court of Claims to transfer a complaint seeking more than $10,000 in damages to the court’s administrative docket. Beyond the lack of explicit authority in the statute, allowing the Court of Claims to make such a transfer based on a preliminary assessment of the claimant’s damages is inconsistent with the text of the statute and the context in which it was enacted. It is true that, as the court noted in this case, R.C. 2743.10(A) specifies that claims against the state for $10,000 or less “shall be determined administratively,” but R.C. 2743.10(B) also
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specifies that such claims “shall be commenced by filing with the clerk on complaint forms prescribed by the supreme court.” In the present case, Bishop did not commence his claim by filing on the specified form and did not claim damages of $10,000 or less. Instead, Bishop filed a complaint seeking compensatory damages of $217,228.09 and an equal amount of punitive damages.3 Therefore, Bishop’s complaint was a civil action against the state for more than $10,000, and the Court of Claims exceeded its statutory authority by transferring the case to its administrative docket for determination by the clerk of court based on a preliminary assessment of the value of Bishop’s alleged damages.4
{¶ 26} Accordingly, we sustain Bishop’s second and third assignments of error.5
{¶ 27} Having sustained Bishop’s second and third assignments of error, his first assignment of error, asserting that the court abused its discretion by stating that the loss of his photographs was inherently sentimental, is rendered moot. IV. Conclusion
{¶ 28} For the foregoing reasons, we sustain Bishop’s second and third assignments of error and conclude that his first assignment of error is rendered moot. We reverse the
3 R.C. 2743.03(D) and L.C.C.R. 1 state that the Rules of Civil Procedure shall govern practice and procedure
in all actions in the Court of Claims, except insofar as inconsistent with R.C. Chapter 2743. Civ.R. 8(A) requires in relevant part that “[i]f [a] party seeks more than twenty-five thousand dollars, the party shall so state in the pleading but shall not specify in the demand for judgment the amount of recovery sought . . . . At any time after the pleading is filed and served, any party from whom monetary recovery is sought may request in writing that the party seeking recovery provide the requesting party a written statement of the amount of recovery sought. Upon motion, the court shall require the party to respond to the request.” Here, Bishop claimed damages in excess of $25,000. He also provided a written statement of the amount of recovery sought. Nothing more was required of him with regards to his claimed value of damages upon the filing of the complaint.
4 We acknowledge that this court has referred to the Court of Claims having inherent authority to manage its
own docket. See Bandaru v. State, 2024-Ohio-1490, ¶ 8 (10th Dist.) (referring to trial courts’ inherent power to manage their dockets in an appeal from a decision of the Court of Claims granting a motion to strike a motion for new trial); A.M. v. Miami Univ., 2017-Ohio-8586, ¶ 21 (10th Dist.) (referring to trial courts’ inherent power to manage their dockets when addressing whether the Court of Claims abused its discretion by striking a brief in opposition to a motion for summary judgment and denying a motion for leave to supplement the brief in opposition). Notwithstanding the general principle that a trial court has inherent authority to manage its docket, we conclude that the specific statutory framework set forth in R.C. 2743.10 for administrative determination of certain claims supersedes any inherent docket-management authority possessed by the Court of Claims.
5 Our decision is limited to the narrow circumstance of considering a motion to transfer to the administrative
docket. We do not in any way opine as to the actual value of damages in this case—or as to whether damages are more or less than $10,000, the value claimed in the complaint, some other value, or $0. We also do not opine as to any caselaw addressing sentimental value. We leave that determination, in the first instance, to the Court of Claims if it ultimately determines ODRC to be liable.
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order of the Court of Claims of Ohio to the extent it transferred Bishop’s negligence claims to the court’s administrative docket and remand this matter to that court for further proceedings consistent with law and this decision.
Judgment reversed in part;
cause remanded.
BEATTY BLUNT and JAMISON, JJ., concur.