State ex rel. Ames v. Kinsman Twp. Bd. of Trustees

2026 Ohio 605
Ohio Court of Appeals·Decided February 23, 2026·No. 2025-T-0051·Published

Opinion

[Cite as State ex rel. Ames v. Kinsman Twp. Bd. of Trustees, 2026-Ohio-605.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT TRUMBULL COUNTY

STATE OF OHIO ex rel. CASE NO. 2025-T-0051 BRIAN M. AMES,

Relator-Appellant, Civil Appeal from the Court of Common Pleas

BRIAN M. AMES,

Plaintiff-Appellant, Trial Court No. 2024 CV 02269 - vs -

KINSMAN TOWNSHIP BOARD OF TRUSTEES,

Respondent-Appellee.

OPINION AND JUDGMENT ENTRY

Decided: February 23, 2026 Judgment: Reversed and remanded

Brian M. Ames, pro se, 2632 Ranfield Road, Mogadore, OH 44260 (Relator-Appellant).

Christine C. Davis, 8561 Turner Mullen Road, Kinsman, OH 44428 (For Respondent- Appellee).

JOHN J. EKLUND, J.

{¶1} Appellant, Brian Ames, individually and in the name of the State of Ohio (ex relator), appeals the judgment of the Trumbull County Court of Common Pleas dismissing his “Verified Complaint in Mandamus for Preparation of Full and Accurate Meeting Minutes and in Declaratory Judgment and Injunction for Enforcement of R.C. 121.22,” which he filed against Appellee, Kinsman Township Board of Trustees.

{¶2} Appellant has raised two assignments of error arguing: (1) the trial court erred in granting Appellee’s Second Motion to Dismiss on the basis that he sought relief under R.C. 121.22 in the name of the State of Ohio and because Appellant lacked individual standing to bring a Complaint for public records against Appellee; and (2) the trial court erred in denying his Civ.R. 12(C) Motion for Judgment on the Pleadings.

{¶3} Herein lies the root of the issue before us.

{¶4} First, an action in mandamus is a statutory creature in Ohio. R.C. Ch. 2731.

It begins with an “application” that “must be by petition, in the name of the state on the relation of the person applying . . . .” (Emphasis added.) R.C. 2731.04. There is no “complaint,” verified or otherwise, for a writ of mandamus.

{¶5} On the other hand, Ohio’s Open Meetings Act may be enforced through an action by “any person.” R.C. 121.22(I)(1).

{¶6} One of Appellant’s claims (for a writ of mandamus) requires a “petition”

brought on behalf of the State. Appellant has not done this. The other claim (seeking declaratory and injunctive relief to enforce R.C. 121.22) cannot be brought on behalf of the State of Ohio because no statute provides for that. See Civ.R. 17(A); State ex rel. Ames v. Geauga Cty. Bd. of Dev. Disabilities, 2024-Ohio-5441, ¶ 10-11 (11th Dist.). Appellant filed his Complaint in both his individual capacity and in the name of the State of Ohio.

{¶7} So, Appellant simply tried to do what Civ.R. 18(A) expressly allows, to “join, either as independent or as alternate claims, as many claims . . . as he has against an opposing party.” The central issue, then, is whether Appellant may, in both his individual

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capacity and in the name of the State of Ohio, file a single case that seeks both mandamus relief and declaratory and injunctive relief to enforce R.C. 121.22.

{¶8} Having reviewed the record and the applicable caselaw, we find Appellant’s first assignment of error has merit. The trial court erred as a matter of law in dismissing Appellant’s claims for mandamus and injunctive and declaratory relief. Appellant may bring a claim in the name of the State of Ohio to seek a writ of mandamus compelling a public body to prepare or maintain meeting minutes. R.C. 2731.04; State ex rel. Long v. Cardington Village Council, 2001-Ohio-130, ¶ 34. In addition, “any person,” including Appellant, may bring an action for declaratory and injunctive relief against a public body to enforce R.C. 121.22.

{¶9} However, we also conclude that Appellant may not bring a claim for mandamus relief in the name of the State of Ohio and a claim to enforce R.C. 121.22 in a single case. On remand, pursuant to Civ.R. 21, the trial court should sever the single claim for a Writ of Mandamus, brought in the name of the State of Ohio, from the claim for declaratory and injunctive relief, brought by Appellant individually. They should proceed separately, subject to the trial court’s authority to consolidate the cases pursuant to Civ.R. 42(A).

{¶10} Therefore, the judgment of the Trumbull County Court of Common Pleas is reversed. This matter is remanded to the point of error, i.e. the trial court’s granting Appellee’s Second Motion to Dismiss.

Substantive and Procedural History {¶11} On December 19, 2024, Appellant filed a “Verified Complaint in Mandamus for Preparation of Full and Accurate Meeting Minutes and in Declaratory Judgment and

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Injunction for Enforcement of R.C. 121.22.” Appellant captioned the Complaint in the name of the State of Ohio ex rel. Brian Ames as Relator and also himself in his individual capacity as Plaintiff.

{¶12} In the Complaint, Appellant alleged he had standing under both R.C.

2731.04 and R.C. 121.22(I)(1).

{¶13} Count One of the Complaint alleged that on specified dates Appellee had failed to keep full and accurate meeting minutes in violation of R.C. 121.22(C).

{¶14} Count Two of the Complaint alleged that on specified dates Appellee held executive sessions for an unapproved purpose in violation of R.C. 121.22(G).

{¶15} Appellant’s prayer for relief requested that the trial court:

(a) Issue a declaratory judgment finding that Appellee had violated R.C.

121.22;

(b) Issue an injunction against Appellee for the violations set forth in Count One, enjoining Appellee to maintain full and accurate meeting minutes;

(c) Issue a writ of mandamus ordering Appellee to prepare full and accurate meeting minutes in compliance with R.C. 121.22;

(d) Issue an affirmative injunction against Appellee for the violations set forth in Count Two, enjoining Appellee from holding executive sessions for unauthorized purposes;

(e) Declare all resolutions, rules, or formal actions taken in improper executive session to be invalid pursuant to R.C. 121.22(H);

(f) Order Appellee to pay Appellant a statutory penalty for each violation as mandated by R.C. 121.22(I)(2)(a);

(g) Award Appellant court costs and reasonable attorney fees;

(h) Any other just and equitable relief.

{¶16} On January 14, 2025, Appellee filed its Answer.

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{¶17} On January 14, 2025, Appellee filed a combined Motion to Dismiss and a Motion for Judgment on the Pleadings Pursuant to Civ.R. 12(C) in the Alternative. On February 20, 2025, Appellant filed a response in opposition.

{¶18} On April 3, 2025, the trial court denied Appellee’s combined Motion to Dismiss and Motion for Judgment on the Pleadings.

{¶19} On April 8, 2025, Appellee filed a Second Motion to Dismiss. Citing our opinion in State ex rel. Ames v. Geauga Cty. Bd. of Developmental Disabilities, 2024- Ohio-5441 (11th Dist.), Appellee argued that Appellant could not bring a claim under R.C. 121.22 in the name of the State of Ohio. Appellee also argued that Appellant lacked standing in his individual capacity to bring a claim under R.C. 121.22 because Appellant did “not have a nexus to the township, does not live there, did not attend any of the meetings in the filing, and has alleged no injury to himself in order to achieve standing.”

{¶20} On April 15, 2025, Appellant filed his Response in Opposition to the Second Motion to Dismiss. Appellant argued that his Complaint “join[ed] two actions, one sounding in mandamus and another sounding in declaratory judgment and injunction.” He argued that as Relator, he brought the complaint in mandamus to seek an order compelling Appellee to prepare “full and accurate meeting minutes.” He said paragraph (C) of his prayer for relief sounded in mandamus and was accordingly brought in the name of the State of Ohio and verified by affidavit as required under R.C. 2731.04. Next, he argued that the remaining prayers for relief in his Complaint were brought in his individual capacity for declaratory judgment and an injunction to seek enforcement of R.C. 121.22. He argued that “any person” may bring an action to enforce R.C. 121.22.

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