Deitz v. Shelby Cty. Clerk of Court

2026 Ohio 63
CourtOhio Court of Appeals
DecidedJanuary 12, 2026
Docket17-25-10
StatusPublished

This text of 2026 Ohio 63 (Deitz v. Shelby Cty. Clerk of Court) 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
Deitz v. Shelby Cty. Clerk of Court, 2026 Ohio 63 (Ohio Ct. App. 2026).

Opinion

[Cite as Deitz v. Shelby Cty. Clerk of Court, 2026-Ohio-63.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT SHELBY COUNTY

PAUL DEITZ, CASE NO. 17-25-10

PLAINTIFF-APPELLANT,

v.

CLERK OF COURTS OF SHELBY COUNTY, ET AL., OPINION AND JUDGMENT ENTRY DEFENDANTS-APPELLEES.

Appeal from Shelby County Common Pleas Court Trial Court No. 24CV000296

Judgment Affirmed

Date of Decision: January 12, 2026

APPEARANCES:

Paul Deitz, Appellant

Michael P. Doyle, Jr. for Appellees Case No. 17-25-10

WILLAMOWSKI, J.

{¶1} Plaintiff-appellant Paul Deitz (“Deitz”) filed a pro se appeal of the

judgment of the Shelby County Court of Common Pleas, arguing that the trial court

erred by failing to set aside a condemnation order issued by the Sidney-Shelby

County Board of Health (“SSCBH”). For the reasons set forth below, the judgment

of the trial court is affirmed.

Facts and Procedural History

{¶2} In 2022, Deitz constructed a pole barn on his property and obtained the

Sidney-Shelby County Health Department’s (“SSCHD”) approval for this project.

On April 29, 2024, the builder of Deitz’s pole barn filed a nuisance complaint with

the SSCBH, reporting that Deitz appeared to be using the pole barn as a two-story

dwelling. The complaint stated that the pole barn had not gone through the

appropriate inspections for such use and was not built “to support load bearing walls

up [and] . . . downstairs.” (Doc. 115-10).

{¶3} In response to an inquiry from the SSCHD, Deitz reported that “[t]he

barn is being used as permitted.” (Doc. 115-18). The SSCBH then sent successive

communications to Deitz that directed him to schedule a property evaluation and to

appear at an administrative hearing in July. However, Deitz did not comply with

these directives.

-2- Case No. 17-25-10

{¶4} After Deitz appeared at a board of health meeting in August, the

SSCBH voted to refer this matter to the Shelby County Prosecutor’s Office

(“Prosecutor’s Office”) over his failure to comply with the water system and sewage

treatment rules. Since Deitz had not scheduled a property evaluation, the SSCHD

approached Deitz’s neighbor and obtained permission to enter onto the neighbor’s

property.

{¶5} From a vantage point on this neighbor’s property, SSCHD personnel

observed that the pole barn had “upstairs patio doors, [an] air conditioner, children’s

toys, a shower nozzle, propane tanks, etc.” (Doc. 115-106). The Prosecutor’s

Office then contacted Deitz and sought his cooperation. After no evaluation was

scheduled, a search warrant was obtained.

{¶6} On September 19, 2024, SSCHD personnel went to Deitz’s property

with the search warrant and discovered a number of violations related to the pole

barn. On November 7, 2024, the Prosecutor’s Office sent Deitz a letter that

informed him of these violations and stated that, if these issues went unabated, the

pole barn would be condemned in sixty days.

{¶7} On November 22, 2024, Deitz filed a pro se complaint that named the

Clerk of Courts of Shelby County as a defendant. He later filed an amended

complaint that added employees of the SSCHD and the Prosecutor’s Office as

defendants. In these complaints, he alleged that his constitutional rights were

violated and sought a temporary restraining order.

-3- Case No. 17-25-10

{¶8} On December 10, 2024, Deitz also filed a notice of appeal, challenging

the SSCHD’s decisions. In response, the defendants filed a motion to dismiss

Deitz’s complaint. The trial court later dismissed the claims in Deitz’s complaint

but found that his notice of appeal was sufficient “to constitute an administrative

appeal” of the decisions related to his pole barn. (Doc. 74).

{¶9} At a conference on March 10, 2025, the trial court asked about the

extent of the condemnation order that SSCBH had issued on January 13, 2025. The

text of this order prohibited “any occupancy of the building.” (Doc. 115-143). But

the Prosecutor’s Office indicated that the order was ultimately intended “to prevent

any permanent or temporary personal habitation.” (Doc. 83).

{¶10} On March 13, 2025, the trial court issued a judgment entry that

modified the condemnation order so that Deitz was “entitled to use of his building

for storage of personal property and for animal husbandry.” (Doc. 83). The trial

court also issued an order directing the parties to file briefs on the issues raised by

Deitz in his administrative appeal.

{¶11} On July 2, 2025, the trial court issued a judgment entry, concluding

that (1) Deitz was afforded appropriate procedural due process protections; (2) no

basis existed to exclude the evidence obtained by the administrative search warrant;

and (3) substantial evidence supported a condemnation order against the use of the

pole barn for residential or business purposes.

-4- Case No. 17-25-10

{¶12} Deitz filed his notice of appeal on July 17, 2025. On appeal, he raises

the following five assignments of error:

First Assignment of Error

The court erred by failing to reverse SSCBH’s decision as unconstitutional under Ohio Const. Art. I, §§ 14, 16, ignoring the September 4, 2024, trespass and invalid warrant (July2Amended Decision.pdf, Pages 4-5; March 10, 2025, Transcript, Page 5).

Second Assignment of Error

The court erred by overlooking SSCBH’s bad faith and retaliation, including Lloyd’s complaint, Zimmerman’s conflict, Rindler-Woodruff’s actions, and access restrictions (July 2 Amended Decision, Page 6; Court of Claims, Pages 1-2, 4-5, 7).

Third Assignment of Error

The court erred by affirming the Notice without substantial evidence, ignoring the disconnected septic line and unsigned promissory agreement (March 10, 2025, Transcript, Page 4; Exhibit A, Page 154).

Fourth Assignment of Error

The court misapplied deference, evading full review (July 2 Amended Decision, Pages 3-4).

Fifth Assignment of Error

The court failed to address access restrictions chilling petition rights (December 6, 2024, Mumford memo; April 25, 2025, emails/memo; August 7, 2025, affidavit).

-5- Case No. 17-25-10

{¶13} Deitz asserts that the trial court erred by failing to reverse the

SSCBH’s order on the grounds that the government engaged in unconstitutional

actions, including activities that rendered the search warrant invalid.

Legal Standard

{¶14} The protections of the Fourth Amendment to the United States

Constitution “extend to administrative searches.” Dawson v. City of Richmond

Heights, 2018-Ohio-1301, ¶ 16 (8th Dist.). In this context,

[p]robable cause to issue an administrative warrant for entry into premises is the subject of a flexible standard of reasonableness given the agency’s particular demand for access and the public need for effective enforcement of the regulation involved.

Bd. of Trs. Blanchard Twp. v. Simon, 2023-Ohio-1704, ¶ 32 (3d Dist.), quoting State

v. Finnell, 115 Ohio App.3d 583, 589 (1st Dist. 1996). Further,

the evidence of a specific violation required to establish administrative probable cause must ‘show that the proposed inspection is based upon a reasonable belief that a violation has been or is being committed.’

Dawson at ¶ 17, quoting W. Point-Pepperell, Inc. v. Donovan, 689 F.2d 950, 958

(11th Cir. 1982). See R.C. 2933.21(F). In deciding whether to issue a search

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2026 Ohio 63, Counsel Stack Legal Research, https://law.counselstack.com/opinion/deitz-v-shelby-cty-clerk-of-court-ohioctapp-2026.