State ex rel. Hogan v. Hoying

CourtOhio Court of Appeals
DecidedJune 25, 2026
Docket26AP-98
StatusPublished

This text of State ex rel. Hogan v. Hoying (State ex rel. Hogan v. Hoying) 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
State ex rel. Hogan v. Hoying, (Ohio Ct. App. 2026).

Opinion

[Cite as State ex rel. Hogan v. Hoying, 2026-Ohio-2420.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Tremain Hogan, :

Relator, : No. 26AP-98

v. : (REGULAR CALENDAR)

Lisa Hoying, Chair, :

Respondent. :

D E C I S I O N

Rendered on June 25, 2026

On brief: Tremain Hogan, pro se.

On brief: [Andy Wison], Attorney General, Jennifer A. Driscoll, and Daniel H. Huston, for respondent. ____ IN MANDAMUS ON RESPONDENT’S MOTION TO DISMISS DINGUS, J. {¶ 1} Relator, Tremain Hogan, has commenced this original action seeking a writ of mandamus against respondent, Lisa Hoying, in her capacity as chair of the Ohio Parole Board. Hogan alleges the Adult Parole Authority violated his rights under the Ohio and United States Constitutions by failing to hold a revocation hearing before giving him a residential sanction for a post-release control violation. {¶ 2} This matter was referred to a magistrate of this court, pursuant to Civ.R. 53(C) and Loc.R. 13(M), of the Tenth District Court of Appeals. Respondent filed a motion to dismiss, pursuant to Civ.R. 12(B)(6), for failure to state a claim upon which relief can be granted. The magistrate issued the appended decision, including findings of fact and conclusions of law, recommending this court grant respondent’s motion to dismiss. No objections have been filed to that decision. No. 26AP-98 2

{¶ 3} Finding no error of law or other defect on the face of the magistrate’s decision, this court adopts the magistrate’s decision as our own, including the findings of fact and conclusions of law. In accordance with the magistrate’s decision, we grant respondent’s motion to dismiss. Motion to dismiss granted; action dismissed.

EDELSTEIN and LELAND, JJ., concur. No. 26AP-98 3

APPENDIX

Relator, :

v. : No. 26AP-98

Lisa Hoying, Chair, : (REGULAR CALENDAR)

MAGISTRATE’S DECISION

Rendered on April 16, 2026

Tremain Hogan, pro se.

Dave Yost, Attorney General, and Jennifer A. Driscoll, for respondent. ____

IN MANDAMUS ON RESPONDENT’S MOTION TO DISMISS

{¶ 4} Relator Tremain Hogan has filed a petition for writ of mandamus against respondent Lisa Hoying, in her capacity as chair of the Ohio Parole Board (“parole board”). Hogan alleges the Adult Parole Authority (“APA”) violated his rights under the Ohio and United States Constitutions by failing to hold a revocation hearing before giving Hogan a residential sanction for a postrelease control violation. Hoying has filed a motion to dismiss. Because Hogan has failed to strictly comply with the inmate filing requirements in R.C. 2969.25(C), the magistrate recommends granting Hoying’s motion and dismissing Hogan’s petition. No. 26AP-98 4

I. Findings of Fact

{¶ 5} 1. Hogan filed his petition for writ of mandamus on February 11, 2026. {¶ 6} 2. At the time of filing, Hogan was an inmate at Lorain Correctional Institution in Grafton, Ohio. {¶ 7} 3. The parole board is an administrative subsection of the APA, which itself is a bureau-level section of the Division of Parole and Community Services of the Department of Rehabilitation and Correction (“DRC”). See R.C. 5149.02. {¶ 8} 4. Hoying, who is sued in her official capacity as chair of the parole board, is a government employee for purposes of R.C. 2969.21 et seq. {¶ 9} 5. In his petition, Hogan asserted entitlement to relief because “[t]he APA violated [Hogan’s] 14th [and] 4th Amendment rights when he was illegally placed in VOA Mansfield without a revocation hearing.” (Petition at ¶ 7.) Hogan alleged that the location where he was placed met the requirements to be considered a secured locked facility. Hogan also asserted that he was denied the opportunity to present witnesses at a revocation hearing. Hogan requested that all violations obtained due to the allegedly illegal placement in the Mansfield VOA be vacated and that he be placed back on postrelease control. {¶ 10} 6. Alongside his petition, Hogan provided an affidavit of indigency. The certified cashier’s statement attached to Hogan’s petition does not set forth the balance in Hogan’s inmate account for each of the preceding six months. {¶ 11} 7. On March 24, 2026, Hoying filed a motion to dismiss pursuant to Civ.R. 12(B)(6).

II. Discussion and Conclusions of Law

{¶ 12} Hoying has moved to dismiss Hogan’s petition for failure to state a claim upon which relief can be granted pursuant to Civ.R. 12(B)(6).

A. Standard for Reviewing a Motion to Dismiss for Failure to State a Claim

{¶ 13} A motion to dismiss for failure to state a claim under Civ.R. 12(B)(6) is procedural and tests the sufficiency of the petition or complaint. See State ex rel. Hanson v. Guernsey Cty. Bd. of Commrs., 1992-Ohio-73, ¶ 9, citing Assn. for the Defense of the Washington Local School Dist. v. Kiger, 42 Ohio St.3d 116, 117 (1989). When ruling No. 26AP-98 5

on a Civ.R. 12(B)(6) motion, a court may consider certain “documents attached to or incorporated into the complaint.” State ex rel. Gordon v. Summit Cty. Court of Common Pleas, 2025-Ohio-2927, ¶ 8. See Civ.R. 10(C) (“A copy of any written instrument attached to a pleading is a part of the pleading for all purposes.”). A court reviewing the sufficiency of a complaint in resolving a Civ.R. 12(B)(6) motion must presume all factual allegations in the complaint to be true and make all reasonable inferences in favor of the nonmoving party. Mitchell v. Lawson Milk Co., 40 Ohio St.3d 190, 192 (1988).

B. Inmate Filing Requirements

{¶ 14} Hoying asserts Hogan’s petition must be dismissed because he failed to comply with the requirement in R.C. 2969.25(C) to submit a statement that sets forth the balance in his inmate account for each of the preceding six months, as certified by the institutional cashier. {¶ 15} R.C. 2969.25(A) and (C) provide procedural requirements for inmates commencing a civil action or appeal against a government entity or employee. See State ex rel. Foster v. Foley, 2022-Ohio-3168, ¶ 10; Fuqua v. Williams, 2003-Ohio-5533, ¶ 3 (stating that the “provisions in R.C. 2969.21 through 2969.27 were enacted . . . effective October 17, 1996, and appear to be Ohio’s version of the Federal Prison Litigation Reform Act”). These procedural requirements include the filing of an affidavit of prior civil actions under R.C. 2969.25(A) and an affidavit of waiver and affidavit of indigency under R.C. 2969.25(C). As acknowledged by this Court, “[t]he purpose of R.C. 2969.21 through 2969.27 is to curb inmate litigation.” Slider v. Dept. of Rehab. & Corr., 1999 Ohio App. LEXIS 2999, at *7 (10th Dist. June 29, 1999). {¶ 16} With regard to the requirements for an affidavit of indigency, R.C. 2969.25(C) provides as follows: If an inmate who files a civil action or appeal against a government entity or employee seeks a waiver of the prepayment of the full filing fees assessed by the court in which the action or appeal is filed, the inmate shall file with the complaint or notice of appeal an affidavit that the inmate is seeking a waiver of the prepayment of the court’s full filing fees and an affidavit of indigency. The affidavit of waiver and the affidavit of indigency shall contain all of the following: (1) A statement that sets forth the balance in the inmate No. 26AP-98 6

account of the inmate for each of the preceding six months, as certified by the institutional cashier; (2) A statement that sets forth all other cash and things of value owned by the inmate at that time. R.C. 2969.25(C). Definitions pertaining to R.C. 2969.25 are contained in R.C. 2969.21. {¶ 17} Compliance with the inmate filing requirements in R.C. 2969.25 is mandatory, and failure to comply compels dismissal. State ex rel. Bey v. Bur.

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Bluebook (online)
State ex rel. Hogan v. Hoying, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-hogan-v-hoying-ohioctapp-2026.