Smith v. State

2024 Ohio 1195, 241 N.E.3d 309
CourtOhio Court of Appeals
DecidedMarch 29, 2024
Docket22CA011915
StatusPublished

This text of 2024 Ohio 1195 (Smith v. State) 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
Smith v. State, 2024 Ohio 1195, 241 N.E.3d 309 (Ohio Ct. App. 2024).

Opinion

[Cite as Smith v. State, 2024-Ohio-1195.]

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

NANCY SMITH, et al. C.A. No. 22CA011915

Appellees

v. APPEAL FROM JUDGMENT ENTERED IN THE STATE OF OHIO COURT OF COMMON PLEAS COUNTY OF LORAIN, OHIO Appellant CASE No. 22CV205613

DECISION AND JOURNAL ENTRY

Dated: March 29, 2024

CARR, Judge.

{¶1} The Ohio Attorney General appeals orders of the Lorain County Court of Common

Pleas that concluded the State of Ohio is represented by the Lorain County Prosecutor’s Office in

this action. This Court reverses.

I.

{¶2} In the 1990’s Nancy Smith and Joseph Allen were convicted of sexually abusing

young children enrolled in a Lorain County Head Start program. Smith was convicted of two

counts of gross sexual imposition, one count of rape, one count of attempted rape, and two counts

of complicity to rape. Allen was convicted of four counts of rape, three counts of felonious sexual

penetration, and one count of gross sexual imposition. Allen spent over 20 years in prison and

Smith spent almost 15 years in prison.

{¶3} In February 2022, Smith’s and Allen’s motions for a new trial were granted, and

the Prosecutor’s Office dismissed the charges against them. Subsequently, Smith and Allen filed 2

complaints to be declared wrongfully imprisoned individuals under R.C. 2743.48; the cases were

ultimately consolidated. The Prosecutor’s Office answered, admitting all of the allegations in the

complaints, and prayed that the trial court declare Smith and Allen to be wrongfully imprisoned

individuals. The Prosecutor’s Office and counsel for Smith and Allen also filed joint stipulations

and a joint motion seeking declarations that Smith and Allen were wrongfully imprisoned

individuals.

{¶4} After the Prosecutor’s Office answered, the Attorney General entered a notice of

appearance on behalf of the State and also filed an answer contesting the petitions. The Attorney

General objected to the stipulations and joint motion, arguing that under R.C. 2743.48(B), it was

the sole entity authorized to represent the State. On the same basis, the Attorney General moved

the trial court to strike the answers filed by the Prosecutor’s Office. After the Attorney General

propounded discovery requests upon the petitioners, they moved to strike the requests.

{¶5} On October 6, 2022, the trial court denied the Attorney General’s motion to strike

the answers. In doing so, the trial court noted that “the primary dispute arises over the entity that

is to represent the [S]tate in this matter.” Six days later, the trial court also granted Smith’s and

Allen’s motion to strike the Attorney General’s discovery requests and denied the Attorney

General’s motion to compel based on its conclusion that the Prosecutor’s Office was the

appropriate entity to represent the State. The Attorney General appealed, assigning one error for

this Court’s review.

II.

ASSIGNMENT OF ERROR

THE OHIO ATTORNEY GENERAL’S OFFICE IS THE REAL PARTY IN INTEREST IN WRONGFUL IMPRISONMENT CASES, PURSUANT TO R.C. [] 2743.48, BECAUSE IT IS THE STATE OF OHIO THAT BEARS THE RISK OF LOSS AND THE ULTIMATE FINANCIAL BURDEN FOR A 3

DECLARATION THAT A PERSON IS/WAS A WRONGFULLY IMPRISONED INDIVIDUAL.

{¶6} Although framed in terms of whether the Attorney General is the real party in

interest, the substance of the Attorney General’s assignment of error is that the trial court erred in

concluding that the State could be represented by the Prosecutor’s Office in this matter. Further,

the Attorney General asserts that, because that determination was erroneous, the rulings which

flowed from that conclusion were likewise flawed.

{¶7} This Court reviews questions of statutory interpretation de novo. Elliot v. Durrani,

171 Ohio St.3d 213, 2022-Ohio-4190, ¶ 8. When interpreting a statute, “a court’s objective is to

determine and give effect to the legislative intent.” State v. Pariag, 137 Ohio St.3d 81, 2013-Ohio-

4010, ¶ 10. The intent of the legislature, in turn, “is to be sought first of all in the language

employed.” Zumwalde v. Madeira & Indian Hill Joint Fire Dist., 128 Ohio St.3d 492, 2011-Ohio-

1603, ¶ 22, quoting Slingluff v. Weaver, 66 Ohio St. 621 (1902), paragraph two of the syllabus.

Consequently, when the text of a statute is unambiguous, our inquiry begins and ends with that

text. Elliott at ¶ 8, citing State ex rel. Plain Dealer Publishing Co. v. Cleveland, 106 Ohio St.3d

70, 2005-Ohio-3807, ¶ 38.

{¶8} “The wrongful-imprisonment statute, R.C. 2743.48, was added to the Revised Code

in 1986 by Sub.H.B. No. 609 ‘to authorize civil actions against the state, for specified monetary

amounts, in the Court of Claims by certain wrongfully imprisoned individuals.’” Doss v. State,

135 Ohio St.3d 211, 2012-Ohio-5678, ¶ 10, quoting 141 Ohio Laws, Part III, 5351. “Under the

statutory scheme, a claimant must be determined to be a ‘wrongfully imprisoned individual’ by

the court of common pleas before being permitted to file for compensation against the state of

Ohio in the Court of Claims.” Doss at ¶ 10.

{¶9} R.C. 2743.48(B)(1) currently provides that: 4

A person may file a civil action to be declared a wrongfully imprisoned individual in the court of common pleas in the county where the underlying criminal action was initiated. That civil action shall be separate from the underlying finding of guilt by the court of common pleas. Upon the filing of a civil action to be determined a wrongfully imprisoned individual, the attorney general shall be served with a copy of the complaint and shall be heard.

(Emphasis added.)

{¶10} The parties have argued, below and on appeal, over the meaning of the last sentence

and what it requires. However, we conclude that a different statute easily answers the question

before us. R.C. 2743.14 states that “[t]he attorney general or one of his assistants, or special

counsel appointed by the attorney general, shall represent the state in all actions against the state

permitted by this chapter.” As R.C. 2743.48 falls within Chapter 2743, the plain language of R.C.

2743.14 requires that the attorney general, one of his assistant’s or special counsel appointed by

the attorney general represent the State of Ohio in an action brought against the State asserting an

individual is a wrongly imprisoned individual. See also Wrenn v. Ohio Dept. of Mental Health &

Mental Retardation, 16 Ohio App.3d 160, 164 (10th Dist.1984) (“Under R.C. 2743.14, the

Attorney General is required to represent the state in all actions brought against it.”). This view is

further supported by language in the Fiscal Note & Local Impact Statement for Am.Sub.H.B. No.

411, the bill that most recently revised R.C. 2743.48. Therein, it states that “[t]he bill is likely to

generate additional work for the courts of common pleas, the Ohio Attorney General’s Office

which represents the state in wrongful imprisonment matters, and the state’s Court of Claims which

processes the request for monetary damages.” Ohio Legislative Service Commission, Fiscal Note

& Local Impact Statement, available at

https://www.legislature.ohio.gov/download?key=11088&format=pdf (accessed March 15, 2024).

The document goes on to note that the modifications to the statute “may make more individuals

eligible to file an action to be declared a wrongfully imprisoned individual than otherwise are 5

eligible under current law.

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Related

State v. Pariag
2013 Ohio 4010 (Ohio Supreme Court, 2013)
Doss v. State
2012 Ohio 5678 (Ohio Supreme Court, 2012)
Rhodes v. City of New Philadelphia
2011 Ohio 3279 (Ohio Supreme Court, 2011)
Zumwalde v. Madeira & Indian Hill Joint Fire District
2011 Ohio 1603 (Ohio Supreme Court, 2011)
Griffith v. City of Cleveland
2010 Ohio 4905 (Ohio Supreme Court, 2010)
Wrenn v. Ohio Department of Mental Health & Mental Retardation
474 N.E.2d 1201 (Ohio Court of Appeals, 1984)
Cicco v. Stockmaster
728 N.E.2d 1066 (Ohio Supreme Court, 2000)
State ex rel. Plain Dealer Publishing Co. v. City of Cleveland
106 Ohio St. 3d 70 (Ohio Supreme Court, 2005)
State v. Carswell
114 Ohio St. 3d 210 (Ohio Supreme Court, 2007)
Elliot v. Durrani
2022 Ohio 4190 (Ohio Supreme Court, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 1195, 241 N.E.3d 309, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-state-ohioctapp-2024.