Folley v. Chambers-Smith

2024 Ohio 2391
CourtOhio Court of Appeals
DecidedJune 24, 2024
Docket24CA012077
StatusPublished

This text of 2024 Ohio 2391 (Folley v. Chambers-Smith) 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
Folley v. Chambers-Smith, 2024 Ohio 2391 (Ohio Ct. App. 2024).

Opinion

[Cite as Folley v. Chambers-Smith, 2024-Ohio-2391.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF LORAIN )

DEREK OLANDIS FOLLEY

Petitioner C.A. No. 24CA012077

v.

ANNETTE CHAMBERS-SMITH, ORIGINAL ACTION IN DIRECTOR OF ODRC HABEAS CORPUS

Respondents

Dated: June 24, 2024

PER CURIAM.

{¶1} Derek Folley petitioned this Court for a writ of habeas corpus to compel

Respondents, Annette Chambers-Smith and Warden Stephen Reynolds, to release him from

custody. Respondents moved to dismiss and Mr. Folley responded in opposition. For the

following reasons, this Court grants the motion to dismiss.

Standard to Grant a Motion to Dismiss

{¶2} When this Court reviews a motion to dismiss under Civ.R. 12(B)(6), we must

presume that all of the factual allegations in the petition are true and make all reasonable inferences

in favor of the nonmoving party. State ex rel. Seikbert v. Wilkinson, 69 Ohio St.3d 489, 490 (1994).

A petition can only be dismissed when, having viewed it in this way, it appears beyond doubt that

the petitioner can prove no set of facts that would entitle him to the relief requested. Goudlock v.

Voorhies, 119 Ohio St.3d 389, 2008-Ohio-4787, ¶ 7. With this standard in mind, we begin with

the facts alleged in the petition. C.A. No. 24CA012077 Page 2 of 5

The Petition Asserts Four Bases for Relief

{¶3} According to Mr. Folley’s petition, he “is challenging the trial court final judgment

in which the jury found ‘The Petitioner’ guilty of Two out of the Three Counts to the

indictment[.]” The petition alleges that he objected to multiple trial court errors, including

“Double Jeopardy” and “Multiplicity Indictment” both before and after trial. He also moved to

dismiss because his right to a speedy trial was violated, but, the petition contends, the trial court

erred when it applied the wrong test and denied the motion. The petition alleges that the trial

court’s judgment is void because Mr. Folley was denied due process of law.

{¶4} The petition also contends that Mr. Folley has been held beyond the expiration of

his sentence, another requirement for this Court to grant habeas corpus relief. According to the

petition, if the trial court had sentenced him to 5 years in prison, instead of the 15 year sentence he

received, or if the trial court had vacated his sentence pursuant to his “Multiplicty Indictment”

argument, then Mr. Folley would have already served his maximum sentence.

The Motion to Dismiss Should be Granted

{¶5} Respondents moved to dismiss pursuant to Civ.R. 12(B)(6). They argued that the

petition alleges trial court errors and habeas corpus does not provide a remedy for these claims that

could have been raised in an appeal from the judgment of conviction. Respondents also noted that

habeas corpus provides a remedy only when the petitioner is entitled to immediate release from

confinement and, they argued, Mr. Folley would not be entitled to immediate release based on the

petition’s allegations. We agree with Respondents that the case should be dismissed.

{¶6} State habeas corpus relief is available in specific, extraordinary circumstances.

R.C. Chapter 2725 prescribes the procedure for bringing a habeas corpus action. The petitioner

must file a petition that contains specific, required, information. If the petition fails to state a C.A. No. 24CA012077 Page 3 of 5

claim, this Court should dismiss it. Chari v. Vore, 91 Ohio St.3d 323, 327 (2001). For this Court

to grant the writ, Mr. Folley must demonstrate that there is an unlawful restraint of his liberty and

that he is entitled to immediate release from confinement. Pegan v. Crawmer, 76 Ohio St.3d 97,

99-100 (1996); Plaza v. Black, Slip Opinion No. 2024-Ohio-853, ¶ 4.

{¶7} Mr. Folley has alleged in his petition that he is entitled to the writ of habeas corpus

because of four trial court errors: Double Jeopardy, speedy trial, Due Process, and sentencing. As

will be discussed, habeas corpus does not provide a remedy for any of these alleged errors.

{¶8} To dismiss a petition under Civ.R. 12(B)(6), it must appear beyond doubt from the

petition, after all factual allegations are presumed true and all reasonable inferences are made in

favor of Mr. Folley, that he can prove no set of facts warranting relief. State ex rel. Dehler v.

Sutula, Judge, 74 Ohio St.3d 33, 34 (1995). “A writ of habeas corpus is warranted in certain

extraordinary circumstances ‘where there is an unlawful restraint of a person’s liberty and there is

no adequate remedy in the ordinary course of law.’” Johnson v. Timmerman-Cooper, 93 Ohio

St.3d 614, 616 (2001), quoting Pegan v. Crawmer, 76 Ohio St.3d 97, 99 (1996); Plaza, 2024-

Ohio-853, ¶ 4. In this case, appeal would have provided an adequate remedy for all of the errors

alleged in the petition.

{¶9} We begin with the claim that Mr. Folley is entitled to the writ of habeas corpus

because of a double jeopardy violation. The petition does not identify the alleged double jeopardy

violation, but the specifics are not relevant to our decision. The Ohio Supreme Court has held that

double jeopardy claims are not cognizable in habeas corpus. See e.g. State ex rel. Steele v.

Eppinger, 147 Ohio St.3d 404, 2016-Ohio-5790, ¶ 4; Elersic v. Wilson, 101 Ohio St.3d 417, 2004-

Ohio-1501, ¶ 3. Mr. Folley, like the petitioner in Elersic, had an adequate remedy in the ordinary

course of law by way of appeal to raise a double jeopardy claim. C.A. No. 24CA012077 Page 4 of 5

{¶10} We now turn to Mr. Folley’s claim for relief because of the alleged violation of his

right to a speedy trial. The Supreme Court has held that speedy trial claims are also not cognizable

in habeas corpus. Id. Mr. Folley had an adequate remedy at law to move to dismiss his indictment

and appeal to raise his alleged speedy-trial violation. Jackson v. Wilson, 100 Ohio St.3d 315,

2003-Ohio-6112, ¶ 6-7. Because he had an adequate remedy at law, the alleged speedy trial

violation cannot be raised in a habeas corpus action.

{¶11} Next, we consider Mr. Folley’s claim that he was denied due process of law. This

claim is based on the alleged double jeopardy violation and denial of the right to a speedy trial. In

other words, Mr. Folley alleges that his right to due process was violated by these other trial court

errors. The Ohio Supreme Court has held, however, that habeas corpus does not provide a remedy

for nonjurisdictional claims that can be raised on direct appeal. Christian v. Davis, 171 Ohio St.3d

329, 2023-Ohio-1445, ¶ 5; Bell v. McConahay, 171 Ohio St.3d 564, 2023-Ohio-693, ¶ 12. Thus,

his alleged due process claim cannot support the grant of a writ of habeas corpus.

{¶12} Finally, we conclude with Mr. Folley’s claim that he is entitled to the writ of habeas

corpus because the trial court erred in imposing sentence. The petition contends that the sentencing

errors resulted in a void sentence. The petition did not allege, however, that the sentencing court

lacked jurisdiction over the offense or personal jurisdiction over him. To the contrary, the remedy

Mr. Folley sought was simply to recognize that the trial court’s alleged sentencing error resulted

in a sentence that was too long, not that the trial court lacked jurisdiction to impose a sentence.

{¶13} Thus, Mr. Folley argued that the trial court erred in imposing sentence. His

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Related

State ex rel. Steele v. Eppinger (Slip Opinion)
2016 Ohio 5790 (Ohio Supreme Court, 2016)
State ex rel. Seikbert v. Wilkinson
633 N.E.2d 1128 (Ohio Supreme Court, 1994)
State ex rel. Dehler v. Sutula
656 N.E.2d 332 (Ohio Supreme Court, 1995)
Pegan v. Crawmer
666 N.E.2d 1091 (Ohio Supreme Court, 1996)
Chari v. Vore
744 N.E.2d 763 (Ohio Supreme Court, 2001)
Johnson v. Timmerman-Cooper
757 N.E.2d 1153 (Ohio Supreme Court, 2001)
Jackson v. Wilson
798 N.E.2d 1086 (Ohio Supreme Court, 2003)
Elersic v. Wilson
101 Ohio St. 3d 417 (Ohio Supreme Court, 2004)
State ex rel. Deiter v. McGuire
894 N.E.2d 680 (Ohio Supreme Court, 2008)
Stevens v. Hill
2022 Ohio 2479 (Ohio Supreme Court, 2022)
Bell v. McConahay
2023 Ohio 693 (Ohio Supreme Court, 2023)
Christian v. Davis
2023 Ohio 1445 (Ohio Supreme Court, 2023)
State ex rel. Mitchell v. Fredrick
2024 Ohio 1861 (Ohio Supreme Court, 2024)
Plaza v. Black
2024 Ohio 853 (Ohio Supreme Court, 2024)

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