Costa v. O'Malley

2024 Ohio 2815
CourtOhio Court of Appeals
DecidedJuly 19, 2024
Docket113896
StatusPublished
Cited by1 cases

This text of 2024 Ohio 2815 (Costa v. O'Malley) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Costa v. O'Malley, 2024 Ohio 2815 (Ohio Ct. App. 2024).

Opinion

[Cite as Costa v. O'Malley, 2024-Ohio-2815.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

TABITHA COSTA, :

Petitioner, : No. 113896 v. :

JUDGE THOMAS F. O’MALLEY, : ET AL., : Respondents.

JOURNAL ENTRY AND OPINION

JUDGMENT: PETITION DISMISSED DATED: July 19, 2024

Writ of Habeas Corpus Motion No. 574284 Order No. 576253

Appearances:

Jessica A. L. Camargo, for relator.

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Regina A. Russo, Assistant Prosecuting Attorney, for respondents.

SEAN C. GALLAGHER, J.:

Petitioner, Tabitha Costa, seeks a writ of habeas corpus ordering her

immediate release from jail after she was found in contempt of court and sanctioned to 30 days in jail, which was later reduced to a 12-day jail sentence. Respondents,

Michelle Henry, Warden of the Cuyahoga County Jail, Judge Thomas O’Malley, and

Magistrate Eleanore Hilow, ask this court to dismiss the action on numerous

grounds. Because petitioner’s request for relief is moot due to a subsequent

judgment issued by Judge O’Malley and a stay of the underlying judgments entered

in an appeal, the case is sua sponte dismissed and respondents’ motion to dismiss is

denied as moot.

Underlying Facts and Case Procedure

On May 3, 2024, petitioner filed a petition for writ of habeas corpus

naming Judge O’Malley and Magistrate Hilow as respondents. The petition alleged

that respondents presided over a juvenile court case involving one of petitioner’s

children. In that case, emergency temporary custody of one of petitioner’s children

was awarded to Cuyahoga County Department of Children and Family Services (“the

agency”) on February 21, 2024, by order of a magistrate. The child was still not in

the agency’s custody by March 15, 2024, when Magistrate Hilow issued an order

requiring petitioner to appear before the court and show cause why she should not

be held in contempt of court for failing to relinquish custody of the child. Petitioner

did not appear at that hearing. Magistrate Hilow issued an order finding petitioner

in contempt and issued an arrest warrant to bring her before the court. That order

was adopted by Judge O’Malley on April 11, 2024. On April 25, 2024, after petitioner

was arrested pursuant to warrant and brought before the court, a hearing was held.

On April 26, 2024, Magistrate Hilow issued a decision finding petitioner in direct contempt and imposed a 30-day jail sanction with credit for three days. The petition

stated that petitioner was taken into custody as a result of the magistrate’s order and

remained in jail at the time the petition was filed.

The same day that the petition was filed, this court issued a journal

entry ordering petitioner to file an amended petition that corrected various

irregularities by 12:00 p.m. on May 6, 2024. The entry also ordered the return of

writ by 12:00 p.m. on May 7, 2024, and set the matter for hearing on May 9, 2024.

The entry also ordered petitioner’s immediate release and stayed the order that

imposed a jail sanction until the habeas matter was resolved.

Petitioner timely filed an amended petition that fixed procedural

irregularities and alleged largely the same facts as in the original petition. The

amended petition added Warden Henry as a respondent. Respondents timely filed

a return of writ and motion to dismiss, arguing that Judge O’Malley and Magistrate

Hilow were improper parties to the action, Judge O’Malley and Magistrate Hilow

had jurisdiction in the underlying matter to impose a sanction for contempt, and

that petitioner has an adequate remedy at law precluding relief in mandamus. They

also argued that the petition was moot because petitioner was no longer in Warden

Henry’s custody.

A hearing was conducted on May 9, 2024. There, the parties

presented arguments about the petition and respondents’ jurisdiction to hold

petitioner in custody. Following the hearing, on May 10, 2024, this court issued an

order directing Judge O’Malley to review Magistrate Hilow’s contempt order pursuant to petitioner’s motion for immediate review filed in the underlying action

on May 8, 2024. The order also continued the stay of the magistrate’s order of

contempt. On May 24, 2024, petitioner filed a notice of decision wherein Judge

O’Malley denied petitioner’s motion for immediate review, affirmed the magistrate’s

finding of contempt, but shortened the jail term to 12 days. On May 28, 2024, this

court issued an order staying the trial court’s decision in relation to petitioner’s

confinement and directed Judge O’Malley to rule on pending objections to the

magistrate’s decision by June 28, 2024. Judge O’Malley has since entered an order

on the objections to the magistrate’s decision.

Relief in Habeas Corpus

The writ of habeas corpus “is for the purpose of determining the

legality of the restraint or custody under which a person is held.” In re Lockhart,

157 Ohio St. 192 (1952), paragraph two of the syllabus. In the present case before

us, that means we examine the legality of the order or orders under which petitioner

is being held in confinement for contempt within the confines of whether relief in

habeas corpus is available. Id. at 194. Additionally, the writ of habeas corpus is an

extraordinary remedy that is only available when there is no other adequate remedy

at law. State ex rel. Harris v. Anderson, 76 Ohio St.3d 193, 194 (1996), citing State

ex rel. Pirman v. Money, 69 Ohio St.3d 591, 593 (1994).

A court may sua sponte dismiss a petition that seeks a writ where it is

frivolous or the petitioner obviously cannot prevail. State ex rel. Edwards v. Toledo

City School Dist. Bd. of Edn., 72 Ohio St.3d 106, 108 (1995). Such a dismissal is governed by the standard established in Civ.R. 12(B)(6). A court may dismiss a

petition when, presuming all factual allegations in the petition as true and

construing all reasonable inferences in favor of the petitioner, it appears beyond

doubt that the petitioner can prove no set of facts entitling them to relief. State ex

rel. Squire v. Phipps, 2023-Ohio-3950, ¶ 35 (10th Dist.).

Generally, a court is limited to the petition and facts alleged therein

when determining a motion to dismiss. State ex rel. Ames v. Summit Cty. Court of

Common Pleas, 2020-Ohio-354, ¶ 5. However, a court is not so limited when

deciding whether a claim is moot. Id. “‘An event that causes a case to become moot

may be proved by extrinsic evidence.’” Lundeen v. Turner, 2020-Ohio-274, ¶ 7 (8th

Dist.), quoting State ex rel. Hawkins v. Haas, 2014-Ohio-5196, ¶ 4, fn. 1, citing State

ex rel. Brown v. Ohio Dept. of Rehab. & Corr., 2014-Ohio-2348, ¶ 2, fn. 1,

citing Pewitt v. Lorain Corr. Inst., 64 Ohio St.3d 470, 472 (1992). Similarly, when

deciding an action for extraordinary relief, a court should consider facts and

circumstances that exist at the time it makes its determination, not as they existed

at the time the petition was filed. State ex rel. Gilliam v. Cuyahoga Cty. Court of

Common Pleas, 1997 Ohio App. LEXIS 590, *3 (8th Dist. Feb. 20, 1997).

In general, “‘“[a] case is moot when the issues presented are no longer

‘live’ or the parties lack a legally cognizable interest in the outcome.”’” State ex rel.

Ames at ¶ 8, quoting State ex rel. Gaylor, Inc. v. Goodenow, 2010-Ohio-1844, ¶ 10-

11, quoting Powell v.

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Bluebook (online)
2024 Ohio 2815, Counsel Stack Legal Research, https://law.counselstack.com/opinion/costa-v-omalley-ohioctapp-2024.