State ex rel. McCarley v. Dept. of Rehab. & Corr.

2024 Ohio 2747, 175 Ohio St. 3d 454
CourtOhio Supreme Court
DecidedJuly 23, 2024
Docket2023-1271
StatusPublished
Cited by4 cases

This text of 2024 Ohio 2747 (State ex rel. McCarley v. Dept. of Rehab. & Corr.) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State ex rel. McCarley v. Dept. of Rehab. & Corr., 2024 Ohio 2747, 175 Ohio St. 3d 454 (Ohio 2024).

Opinion

[This opinion has been published in Ohio Official Reports at 175 Ohio St.3d 454.]

THE STATE EX REL . MCCARLEY, APPELLANT, v. OHIO DEPARTMENT OF REHABILITATION AND CORRECTION, APPELLEE. [Cite as State ex rel. McCarley v. Dept. of Rehab. & Corr., 2024-Ohio-2747.] Mandamus—Court of appeals did not err by relying on documents attached to appellant’s complaint when granting appellee’s motion for judgment on the pleadings—Because appellant failed to show that Rules Infraction Board’s guilty finding imposed an atypical and significant hardship on him, mandamus was not proper—Court of appeals’ judgment affirmed. (No. 2023-1271—Submitted May 7, 2024—Decided July 23, 2024.) APPEAL from the Court of Appeals for Franklin County, No. 22AP-111, 2023-Ohio-3175. __________________ The per curiam opinion below was joined by KENNEDY, C.J., and FISCHER, DEWINE, DONNELLY, STEWART, BRUNNER, and DETERS, JJ.

Per Curiam. {¶ 1} Appellant, Willard McCarley, is an inmate at the Marion Correctional Institution (“MCI”). McCarley appeals the Tenth District Court of Appeals’ judgment denying his request for a writ of mandamus to compel appellee, the Ohio Department of Rehabilitation and Correction (“DRC”), to vacate a decision of MCI’s Rules Infraction Board (the “RIB”) that found him guilty of violating an inmate rule of conduct. Because McCarley cannot demonstrate that he is entitled to extraordinary relief in mandamus, we affirm the Tenth District’s judgment. I. BACKGROUND {¶ 2} According to the allegations in McCarley’s mandamus complaint, he submitted an Inmate Confidential Statement form to an MCI institutional SUPREME COURT OF OHIO

investigator in November 2021, alleging that he had been sexually assaulted by a prison doctor during an exam. The investigator’s office subsequently issued a conduct report accusing McCarley of violating Rule 27, an inmate rule of conduct. See former Adm.Code 5120-9-06(C)(27) (“[g]iving false information or lying to departmental employees”).1 The conduct report states that McCarley “provided a written statement to the Investigator’s Office which contained a false PREA[2] Allegation against a medical staff member at MCI. His PREA allegation was investigated and determined to [be] unfounded.” {¶ 3} On November 15, 2021, an administrative hearing was held, and the RIB found McCarley guilty of violating former Rule 27 by providing a written statement to an institutional investigator that contained a false allegation against an MCI staff member. Consequently, McCarley was allegedly placed in “discipline control” for a period of 14 days. He unsuccessfully appealed the guilty finding, first to the MCI warden and then to DRC’s chief legal counsel, on the basis that no supporting evidence was introduced at the hearing. The warden affirmed the RIB’s decision, stating that “an unfounded finding of a PREA investigation is sufficient information to find/support a violation of Rule 27.” DRC’s chief legal counsel also affirmed the RIB’s guilty finding and advised that “[t]o the extent Mr. McCarley feels that his PREA claim was not fully addressed or investigated, . . . [t]he RIB appeals process is not a proper method to continue such a claim.” {¶ 4} McCarley filed an original action in the Tenth District, requesting a writ of mandamus to compel DRC to vacate the RIB’s decision finding him guilty of violating former Rule 27. In his complaint, McCarley claims (1) that he has a clear legal right to “due process and a not-guilty finding when no evidence was

1. Effective August 7, 2023, former Adm.Code 5120-9-06(C)(27) was renumbered Adm.Code 5120-9-06(C)(34), and it now provides that an inmate commits a rule violation by “[g]iving false information or lying to a staff member or non-incarcerated person.”

2. “PREA” is an apparent reference to the Prison Rape Elimination Act, 34 U.S.C. 30301 et seq.

2 January Term, 2024

proffered that he lied on his inmate statement,” (2) that DRC has a clear legal duty to find him not guilty under Adm.Code 5120-9-06 “when no evidence existed [to prove that he] lied on his inmate statement warranting a Rule 27 conduct violation,” and (3) that no adequate remedy in the ordinary course of the law exists by which he can challenge the guilty finding. McCarley attached multiple exhibits to his complaint. {¶ 5} DRC answered the complaint and then moved for judgment on the pleadings under Civ.R. 12(C) “for two independent reasons”: (1) McCarley failed to comply with the mandatory filing requirements of R.C. 2969.25(A)3 and (2) he failed to state a cognizable claim for relief in mandamus. McCarley opposed DRC’s motion for judgment on the pleadings. He additionally filed a document captioned “Relator’s Submition [sic] of Evidence,” which included, among other items, many of the same exhibits that were attached to his complaint. {¶ 6} The Tenth District referred the matter to a magistrate, who found no merit to DRC’s argument that McCarley failed to comply with the filing requirements of R.C. 2969.25(A), because McCarley had filed an appropriate affidavit. The magistrate nonetheless recommended that the court grant DRC’s motion for judgment on the pleadings and deny the writ, because McCarley could not demonstrate that he had a clear legal right to a not-guilty finding or that DRC had a clear legal duty to provide additional due-process protections. McCarley filed objections to the magistrate’s decision. The court of appeals sustained McCarley’s objection that the magistrate had failed to analyze whether he was entitled to a writ based on his allegation that there was insufficient evidence to support the RIB’s guilty finding, and it remanded the case to the magistrate to make that finding. The Tenth District adopted the rest of the magistrate’s decision.

3. R.C. 2969.25(A) generally requires that when an inmate commences in a court of appeals or court of common pleas a civil action or appeal against a government entity or employee, the inmate must file an affidavit listing all civil actions the inmate has filed in the previous five years.

3 SUPREME COURT OF OHIO

{¶ 7} On remand, the magistrate again recommended that the court grant DRC’s motion for judgment on the pleadings and deny the writ. The magistrate concluded that absent a finding that a constitutionally protected liberty interest was implicated, McCarley could not establish that DRC was under a clear legal duty to vacate the guilty finding based on a claim of insufficient evidence or that he had a clear legal right to the requested relief. The court of appeals overruled McCarley’s objections and adopted the magistrate’s decision, granted DRC’s motion for judgment on the pleadings, and denied McCarley’s request for a writ of mandamus. {¶ 8} McCarley appealed that decision as of right. II. ANALYSIS A. Alternative Arguments {¶ 9} In his first and second propositions of law, McCarley maintains that the Tenth District’s failure to address in its final decision DRC’s argument that McCarley failed to comply with R.C. 2969.25(A) resulted in either a nonfinal order or reversible error. These contentions have no merit. {¶ 10} The Tenth District was not required to address each alternative argument DRC presented in its motion for judgment on the pleadings. See, e.g., State ex rel. Karmasu v. Tate, 83 Ohio App.3d 199, 205 (4th Dist. 1992) (“A trial court is not required to consider any legal theory, or argument, beyond that which will adequately dispose of the case at hand.”). Nevertheless, the magistrate did address McCarley’s R.C. 2969.25(A) argument in his first decision, concluding that McCarley had complied with the statute by filing the required affidavit, and the court of appeals adopted that decision as its own.

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 2747, 175 Ohio St. 3d 454, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-mccarley-v-dept-of-rehab-corr-ohio-2024.