In re Petition of Hicks v. Russo

2025 Ohio 2077
CourtOhio Court of Appeals
DecidedJune 11, 2025
Docket115186
StatusPublished

This text of 2025 Ohio 2077 (In re Petition of Hicks v. Russo) 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
In re Petition of Hicks v. Russo, 2025 Ohio 2077 (Ohio Ct. App. 2025).

Opinion

[Cite as In re Petition of Hicks v. Russo, 2025-Ohio-2077.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

IN RE PETITION OF : LAUREN HICKS, : Relator, No. 115186 : v. : JUDGE JOHN J. RUSSO, : Respondent.

JOURNAL ENTRY AND OPINION

JUDGMENT: PETITION DISMISSED DATED: June 11, 2025

Writ of Mandamus Order No. 585162

Appearances:

Lauren Hicks, pro se.

EILEEN T. GALLAHER, J.:

Relator, Lauren Hicks, pro se, has filed a petition for a writ of

mandamus, seeking to compel respondent, Judge John J. Russo, to issue rulings in

an underlying foreclosure action that has been filed against her, in PennyMac Loan

Svcs., L.L.C. v. Hicks, Cuyahoga C.P. No. CV-23-984447. Because Hicks has already received the relief she could have received through a mandamus claim, rendering

her petition moot, we sua sponte, dismiss Hicks’s petition.

I. Facts and Procedural Background

On April 17, 2025, Hicks, pro se, filed a “general appearance and motion

to dismiss for lack of subject matter jurisdiction” (“motion to dismiss”) in the

underlying foreclosure action. She argued that the case should be dismissed for lack

of subject-matter jurisdiction under R.C. 1901.02 and 1901.08 because “the subject

property is not within the court’s territorial limits.” On May 19, 2025, Hicks filed

(among other documents) (1) a “reply objecting to jurisdiction determination,” (2) a

“demand for findings of fact and conclusions of law pursuant to Ohio Civ.R. 52”

related to her motion to dismiss, (3) a “motion to stay eviction proceedings pending

final ruling on jurisdiction and title” (“motion to stay”), (4) a “notice of

constitutional challenge to state foreclosure and eviction procedures,” and (5) a

“motion to certify constitutional questions to the Ohio Supreme Court” (“motion to

certify constitutional questions”).

On June 3, 2025, Hicks filed her petition for a writ of mandamus

seeking to compel respondent to (1) “[i]ssue a ruling on the territorial and subject

matter challenge raised in CV-23-984447,” “expressly addressing . . . [t]he territorial

subject matter jurisdiction of the Court under R.C. §§ 1901.02 and 1901.18” and

“[t]he constitutional implications of dispossessing Relator without adjudication of

her FDCPA/FCRA claims and private shelter rights,” and (2) “[s]tay all eviction and

enforcement proceedings pending full adjudication of jurisdictional and constitutional issues” in the underlying action. Hicks attached copies of her May 19,

2025 filings and copies of rulings, dated May 20, 2025, and May 22, 2025, denying

certain of her motions to her petition.

II. Law and Analysis

A writ of mandamus is “a writ, issued in the name of the state to an

inferior tribunal, a corporation, board, or person, commanding the performance of

an act which the law specifically enjoins as a duty resulting from an office, trust, or

station.” R.C. 2731.01. It is an extraordinary remedy. To be entitled to mandamus

relief, the relator must establish by clear and convincing evidence that (1) he or she

has a clear legal right to the requested relief, (2) the respondent has a clear legal duty

to provide that relief, and (3) the lack of an adequate remedy in the ordinary course

of the law. State ex rel. Schwarzmer v. Mazzone, 2025-Ohio-1246, ¶ 10; State ex

rel. Duncan v. Chambers-Smith, 2025-Ohio-978, ¶ 10.

A writ of mandamus may be used to compel a court to act, but it cannot

generally be used to dictate the action the court takes. See R.C. 2731.03 (“The writ

of mandamus may require an inferior tribunal to exercise its judgment, or proceed

to the discharge of any of its functions, but it cannot control judicial discretion.”).

Although a writ of mandamus may be used to require a judge to issue a ruling on a

particular matter, it cannot be used to control what decision is issued. Wesley v.

Cuyahoga Cty. Court of Common Pleas, 2020-Ohio-4921, ¶ 10 (8th Dist.); Clough

v. Lawson, 2012-Ohio-5831, ¶ 9 (11th Dist.) (“‘[I]n the context of cases involving a

judge’s duty to rule upon pending motions . . . [a writ of mandamus] cannot be used as a means of mandating a trial judge’s holding on a particular matter; that is, while

the writ will lie to require a judge to dispose of a pending motion, it will not lie to

require a specific ruling.’”), quoting State ex rel. Verbanik v. Girard Mun. Court

Judge Bernard, 2007-Ohio-1786, ¶ 6 (11th Dist.).

Further, a writ of mandamus will not compel the performance of a duty

that has already been performed. State ex rel. S.Y.C. v. Floyd, 2024-Ohio-1387, ¶ 15.

“A court ‘may dismiss a complaint sua sponte and without notice when

the complaint is frivolous or the claimant obviously cannot prevail on the facts

alleged in the complaint.’” State ex rel. Allen v. Goulding, 2019-Ohio-858, ¶ 6,

quoting State ex rel. Brooks v. O’Malley, 2008-Ohio-1118, ¶ 5; see also State ex rel.

Dodson v. Phipps, 2024-Ohio-4928, ¶ 12. A complaint is subject to dismissal sua

sponte when, after presuming the truth of all material factual allegations of the

relator’s petition and making all reasonable inferences in his or her favor, it appears

beyond doubt that that the relator is not entitled to the extraordinary relief

requested. State ex rel. Neal v. Mandros, 2020-Ohio-4866, ¶ 8, citing State ex rel.

Scott v. Cleveland, 2006-Ohio-6573, ¶ 14; State ex rel. Collins v. Kilbane, 2023-

Ohio-1577, ¶ 4 (8th Dist.).

Based on our review of the documents Hicks attached to her petition

and the publicly available online docket for the common pleas court in the

underlying case, respondent denied Hicks’s motion to dismiss on May 5, 2025.1

1 An event that causes a case to become moot may be proved by extrinsic evidence outside the record. State ex rel. Nelson v. Russo, 89 Ohio St.3d 227, 228 (2000) (appellate court may take judicial notice that a writ action is moot); see also State ex rel. Fischer Asset Respondent denied Hicks’s motion to certify constitutional questions on May 20,

2025, and denied her demand for findings of fact and conclusions of law and motion

to stay on May 22, 2025.

In support of her contention that “[m]andamus is appropriate where a

judge fails to rule on a jurisdictional challenge, or refuses to adjudicate a

fundamental constitutional right,” Hicks cites to “State ex rel. Watkins v. Fiorenzo,

114 Ohio App.3d 227 (1996).” That is not a proper citation. The citation to “114 Ohio

App.3d 227 (1996),” is part of State v. Owen, 114 Ohio App.3d 226 (12th Dist. 1996),

in which the appellate court affirmed the trial court’s judgment granting the

defendant’s motion to suppress evidence where the defendant was charged with

driving under the influence. Even if Hicks had intended to refer to State ex rel.

Watkins v. Fiorenzo, 71 Ohio St.3d 259 (1994), in that case, the Ohio Supreme Court

granted a peremptory writ of quo warranto removing the respondent from his

position as Trumbull County Engineer after he was found guilty of theft in office.

Neither of those cases has any application here.

Given that respondent had already ruled on Hicks’s motions when she

filed her petition, Hicks has already received all the relief she could have received

through her mandamus claim, rendering her petition moot. See, e.g., State ex rel.

Mgmt., L.L.C. v. Scott, 2023-Ohio-3891, ¶ 3, fn.

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Bluebook (online)
2025 Ohio 2077, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-petition-of-hicks-v-russo-ohioctapp-2025.