State ex rel. Lower v. Mackey

2025 Ohio 2955
CourtOhio Court of Appeals
DecidedAugust 19, 2025
Docket25AP-212
StatusPublished

This text of 2025 Ohio 2955 (State ex rel. Lower v. Mackey) 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. Lower v. Mackey, 2025 Ohio 2955 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. Lower v. Mackey, 2025-Ohio-2955.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Michael Lower, : No. 25AP-212 Relator, : (REGULAR CALENDAR) v. :

Franklin County Common Pleas, : Probate Court, Judge Jeffrey D. Mackey, : Respondent. :

D E C I S I O N

Rendered on August 19, 2025

On brief: Michael Lower, pro se.

On brief: Shayla D. Favor, Prosecuting Attorney, and Brandon Coy Hendrix, for respondent.

IN PROCEDENDO AND/OR MANDAMUS ON OBJECTIONS TO THE MAGISTRATE’S DECISION GRANTING RESPONDENT’S MOTION TO DISMISS MENTEL, J. {¶ 1} Relator, Michael Lower, brought this original action seeking a writ of procedendo and/or mandamus ordering the respondent, Judge Jeffrey D. Mackey, to issue a ruling on the relator’s November 27, 2024 motion to disqualify Magistrate Kelly Green; November 27, 2024 motion to join an interested party; and November 27, 2024 motion for leave to file an amended complaint. {¶ 2} On February 28, 2025, pursuant to Civ.R. 53 and Loc.R. 13(M) of the Tenth District Court of Appeals, this matter was referred to a magistrate of this court. {¶ 3} On March 12, 2025, the respondent filed a motion to dismiss arguing that the relator failed to state a claim as the probate court has ruled on the previously outstanding No. 25AP-212 2

motions. On March 26, 2025, the relator filed a memorandum in opposition arguing that the respondent’s motion should be denied. An amended memorandum in opposition was filed on March 30, 2025. A reply brief was filed on April 10, 2025. {¶ 4} On May 29, 2025, the magistrate issued the appended decision. The magistrate’s decision included findings of fact and conclusions of law and recommended that we grant the respondent’s motion to dismiss the relator’s complaint for a writ of procedendo and/or writ of mandamus. The magistrate found that the relator’s original action seeking a writ of procedendo and/or mandamus to order the respondent to rule on the various motions was moot as the probate court has resolved all of the outstanding motions at issue. “Thus, respondent has performed the act that relator sought to compel, i.e., ruling on relator’s November 27, 2024, motions. Therefore, neither procedendo nor mandamus will lie under these circumstances.” (May 29, 2025 Appended Mag.’s Decision at ¶ 26.) Pursuant to Civ.R. 53(D)(3), the magistrate provided notice to the relator of the opportunity to file written objections within 14 days of the filing of the decision. {¶ 5} On June 10, 2025, the relator filed written objections to the magistrate’s decision. On June 17, 2025, the respondent filed a memorandum in opposition to the relator’s objections. {¶ 6} The relator first raises objections concerning the probate court magistrate and alleges various concerns with her rulings. The relator then argues that the respondent failed to rule on the motions at issue in this case until the relator filed this original action. (Relator’s Obj. at 4.) The relator also contends that the magistrate’s decision in this case was “deficient and lacking in weighted consideration,” and that he failed to address purported violations of the Ohio Code of Judicial Conduct. (Relator’s Obj. at 4.) Finally, the relator presents additional arguments concerning the merits of the case before the probate court and identifies additional filings outside the scope of this action that allegedly remain pending at this time. (Relator’s Obj. at 10.) {¶ 7} Civ.R. 53(D)(4)(d) provides, “[i]f one or more objections to a magistrate’s decision are timely filed, the court shall rule on those objections.” As set forth in Civ.R. 53(D)(4)(d), when ruling on objections, we undertake an independent review of the objected matters “to ascertain that the magistrate has properly determined the factual No. 25AP-212 3

issues and appropriately applied the law.” We may adopt or reject a magistrate’s decision in whole or in part, with or without modification. {¶ 8} Upon review, we agree with the magistrate’s recommendation to grant the respondent’s motion to dismiss. It is well established that a court may take judicial notice of pleadings and orders in related cases not subject to reasonable dispute insofar as they affect the current original action. See, e.g., State ex rel. Brown v. Lynch, 2024-Ohio-3099, ¶ 20, citing State ex rel. Nyamusevya v. Hawkins, 2020-Ohio-2690, ¶ 33 (10th Dist.), citing Evid.R. 201(B). A court may take judicial notice of pleadings that are readily available on the internet. Brown at ¶ 20, citing Draughon v. Jenkins, 2016-Ohio-5364, ¶ 26 (4th Dist.). {¶ 9} Here, the relator filed the three motions at issue on November 27, 2024. We take judicial notice that the respondent denied the relator’s motion to disqualify on March 7, 2025. On March 11, 2025, the respondent denied the relator’s motions for leave to join an interested party and leave to file an amended complaint. As such, we agree with the magistrate that this matter is moot as the “respondent has performed the act that relator sought to compel, i.e., ruling on relator’s November 27, 2024, motions. Therefore, neither procedendo nor mandamus will lie under these circumstances.” (May 29, 2025 Appended Mag.’s Decision at ¶ 26.) {¶ 10} We decline to examine any of the alleged violations of Ohio Code of Judicial Conduct. This court has no authority to address the relator’s claims as “[t]he Supreme Court has the exclusive jurisdiction to address claims of bias or violations of rules of judicial conduct.” State v. Byers, 2025-Ohio-1511, ¶ 50 (10th Dist.), citing State v. Bastawros, 2024-Ohio-2809, ¶ 21 (8th Dist.), citing In re Estate of Wearn, 2023-Ohio-3152, ¶ 15 (8th Dist.). Moreover, any arguments regarding the merits of the original action are moot as the probate court has ruled on the outstanding motions. “[T]he merits of a claim in procedendo will be considered moot when the judicial officer [has] already completed the precise act which the relator sought to compel.” Davis v. Smalheer, 2010-Ohio-6061, ¶ 5 (11th Dist.). Finally, we decline to address the relator’s arguments concerning the matter before the probate court or his concerns regarding other outstanding motions allegedly pending at this time as those issues are outside the scope of this original action. No. 25AP-212 4

{¶ 11} Upon careful review of the magistrate’s decision, an independent review of the record, and due consideration of the relator’s objections, we find the magistrate properly applied the law to the facts. Accordingly, we overrule the relator’s objections and adopt the magistrate’s decision as our own, including the findings of fact and conclusions of law. The relator’s petition for a writ of procedendo/mandamus is dismissed as moot. Objections overruled; case dismissed. DORRIAN and LELAND, JJ., concur. _____________ No. 25AP-212 5

APPENDIX

State ex rel. Michael Lower, :

Relator, :

v. : No. 25AP-212

Franklin County Common Pleas , : (REGULAR CALENDAR) Probate Court, Judge Jeffrey D. Mackey, : Respondent. :

MAGISTRATE’ S DECISION

Rendered on May 29, 2025

Michael Lower, pro se.

Shayla D. Favor, Prosecuting Attorney, and Brandon Coy Hendrix, for respondent.

IN PROCEDENDO AND/OR MANDAMUS ON RESPONDENT’S MOTION TO DISMISS

{¶ 12} Relator, Michael Lower, has filed this original action seeking a writ of procedendo and/or mandamus ordering respondent, Judge Jeffrey D. Mackey, to issue a ruling on relator’s November 27, 2024, motion to disqualify magistrate Kelly Greene; November 27, 2024, motion to join an interested party; and November 27, 2024, motion for leave to file an amended complaint. Respondent has filed a motion to dismiss.

Findings of Fact: No. 25AP-212 6

{¶ 13} 1. Respondent is a public official serving as a judge in the Franklin County Probate Court (“probate court”), in Columbus, Ohio. {¶ 14} 2.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State ex rel. Lester v. Pepple
2011 Ohio 5756 (Ohio Supreme Court, 2011)
State ex rel. Womack v. Marsh
2011 Ohio 229 (Ohio Supreme Court, 2011)
State ex rel. Nyamusevya v. Hawkins
2020 Ohio 2690 (Ohio Court of Appeals, 2020)
State ex rel. Pressley v. Industrial Commission
228 N.E.2d 631 (Ohio Supreme Court, 1967)
State ex rel. Levin v. City of Sheffield Lake
637 N.E.2d 319 (Ohio Supreme Court, 1994)
State ex rel. Dehler v. Sutula
656 N.E.2d 332 (Ohio Supreme Court, 1995)
State ex rel. Miley v. Parrott
671 N.E.2d 24 (Ohio Supreme Court, 1996)
State ex rel. Grove v. Nadel
703 N.E.2d 304 (Ohio Supreme Court, 1998)
State ex rel. Kreps v. Christiansen
725 N.E.2d 663 (Ohio Supreme Court, 2000)
State v. Bastawros
2024 Ohio 2809 (Ohio Court of Appeals, 2024)
State ex rel. Brown v. Lynch
2024 Ohio 3099 (Ohio Court of Appeals, 2024)
State v. Byers
2025 Ohio 1511 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 2955, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-lower-v-mackey-ohioctapp-2025.