State ex rel. Wolfe v. Ohio Dept. of Rehab. & Corr.

2025 Ohio 1033
CourtOhio Court of Appeals
DecidedMarch 25, 2025
Docket24AP-553
StatusPublished

This text of 2025 Ohio 1033 (State ex rel. Wolfe v. Ohio Dept. of Rehab. & Corr.) 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. Wolfe v. Ohio Dept. of Rehab. & Corr., 2025 Ohio 1033 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. Wolfe v. Ohio Dept. of Rehab. & Corr., 2025-Ohio-1033.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Javelen Wolfe, :

Relator, :

v. : No. 24AP-553

Ohio Department of Rehabilitation : (REGULAR CALENDAR) and Correction, : Respondent. :

D E C I S I O N

Rendered on March 25, 2025

Javelen Wolfe, pro se.

Dave Yost, Attorney General, Adam Beckler, and George Horvath, for respondent.

IN MANDAMUS ON REVIEW OF MAGISTRATE’S DECISION

BEATTY BLUNT, J.

{¶ 1} On September 5, 2024, relator, Javelen Wolfe, an inmate at London Correctional Institution in London, Ohio, filed a complaint in the instant mandamus action, and on October 22, 2024, relator filed a motion for a default judgment. On December 9, 2024, respondent, Ohio Department of Rehabilitation and Correction, filed a motion to dismiss, arguing that relator had failed to comply with R.C. 2969.25(A). Pursuant to Civ.R. 53 and Loc.R. 13(M) of the Tenth District Court of Appeals, this matter was referred to a magistrate. On review, the magistrate recommended that we dismiss the action for failure to comply with R.C. 2969.25(A) and deny the motion for default judgment as moot. {¶ 2} Relator has not filed any objection to the magistrate’s decision. “If no timely objections are filed, the court may adopt a magistrate’s decision, unless it determines that No. 24AP-553 2

there is an error of law or other defect evident on the face of the magistrate’s decision.” Civ.R. 53(D)(4)(c). Our review of the magistrate’s decision reveals no error of law or other evident defect. See, e.g., State ex rel. Alleyne v. Indus. Comm., 2004-Ohio-4223, ¶ 32-33 (10th Dist.) (adopting the magistrate’s decision where no objections were filed). {¶ 3} As we have found no error of law or other defect on the face of the magistrate’s decision, we adopt it as our own, including the findings of fact and conclusions of law as they are set forth in the decision. In accordance with the magistrate’s recommendation, respondent’s motion to dismiss is sustained, relator’s petition for writ of mandamus is dismissed, and relator’s motion for default judgment is denied as moot. Respondent’s motion to dismiss sustained; relator’s petition for writ of mandamus dismissed; relator’s motion for default judgment denied as moot.

MENTEL and BOGGS, JJ., concur. No. 24AP-553 3

Ohio Department of Rehabilitation & : (REGULAR CALENDAR)

Correction, :

Respondent. :

MAGISTRATE’S DECISION

Rendered on December 30, 2024

Dave Yost, Attorney General, Adam Beckler, and George Horvath, for respondent.

IN MANDAMUS ON MOTIONS

{¶ 4} Relator Javelen Wolfe seeks a writ of mandamus ordering respondent Ohio Department of Rehabilitation and Correction (“ODRC”) to comply with Wolfe’s request for public records under R.C. 149.43. Wolfe has filed a motion for default judgment. ODRC has filed a motion to dismiss. For the following reasons, the magistrate recommends granting ODRC’s motion to dismiss.

I. Findings of Fact {¶ 5} 1. At the time this action was filed, Wolfe was an inmate incarcerated at London Correctional Institution in London, Ohio. {¶ 6} 2. ODRC is a government entity for purposes of R.C. 2969.21 et seq. No. 24AP-553 4

{¶ 7} 3. Wolfe filed a complaint for mandamus on September 5, 2024. Attached to the complaint was an affidavit of indigency and affidavit of prior actions. {¶ 8} 4. In the complaint, Wolfe alleges that on June 10, 2024, Wolfe sent a letter requesting that ODRC provide a certified copy of the original, unredacted contract between GTL/Viapath and ODRC. Wolfe alleges that ODRC has not answered or responded to the public records request. Wolfe seeks a writ of mandamus ordering ODRC to provide the records, pay $1,000 to Wolfe, and pay court costs for this matter. {¶ 9} 5. On October 21, 2024, a notation on the docket reflected a failure of service. {¶ 10} 6. Wolfe filed a motion for default judgment on October 22, 2024. {¶ 11} 7. On November 12, 2024, a notation on the docket reflected that service of the complaint was made on November 9, 2024. {¶ 12} 8. On December 9, 2024, ODRC filed a motion to dismiss. {¶ 13} 9. On December 23, 2024, Wolfe filed a response to ODRC’s motion to dismiss.

II. Discussion and Conclusions of Law {¶ 14} In its motion to dismiss, ODRC argues that Wolfe’s complaint must be dismissed for lack of compliance with R.C. 2969.25.

A. Inmate Filing Requirements

{¶ 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, 170 Ohio St.3d 86, 2022-Ohio-3168, ¶ 10; Fuqua v. Williams, 100 Ohio St.3d 211, 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 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). {¶ 16} With regard to the affidavit of prior civil actions, R.C. 2969.25(A) provides that “[a]t the time that an inmate commences a civil action or appeal against a government entity or employee, the inmate shall file with the court an affidavit that contains a description of each civil action or appeal of a civil action that the inmate has No. 24AP-553 5

filed in the previous five years in any state or federal court.” To comply with this statute, the filed affidavit must include all of the following: (1) A brief description of the nature of the civil action or appeal; (2) The case name, case number, and the court in which the civil action or appeal was brought; (3) The name of each party to the civil action or appeal; (4) The outcome of the civil action or appeal, including whether the court dismissed the civil action or appeal as frivolous or malicious under state or federal law or rule of court, whether the court made an award against the inmate or the inmate’s counsel of record for frivolous conduct under [R.C. 2323.51], another statute, or a rule of court, and, if the court so dismissed the action or appeal or made an award of that nature, the date of the final order affirming the dismissal or award. R.C. 2969.25(A). {¶ 17} Definitions pertaining to R.C. 2969.25 are contained in R.C. 2969.21. R.C. 2969.21(B)(1) defines a “civil action or appeal against a government entity or employee” as including any of the following: (a) A civil action that an inmate commences against the state, a political subdivision, or an employee of the state or a political subdivision in a court of common pleas, court of appeals, county court, or municipal court; (b) An appeal of the judgment or order in a civil action of the type described in [R.C. 2969.21(B)(1)(a)] that an inmate files in a court of appeals. However, the term “civil action or appeal against a governmental entity or employee” does not include “any civil action that an inmate commences against the state, a political subdivision, or an employee of the state or a political subdivision in the court of claims or the supreme court or an appeal of the judgment or order entered by the court of claims in a civil action of that nature, that an inmate files in a court of appeals or the supreme court.” R.C. 2969.21(B)(2). Importantly, inmates who have not filed a civil action or appeal of a civil action against a government entity or employee in the previous five years need not file the affidavit of prior civil actions required by R.C. 2969.25(A). State ex rel. Wickensimer v. Bartleson, 123 Ohio St.3d 154, 2009-Ohio-4695, ¶ 3. {¶ 18} Compliance with the inmate filing requirements in R.C. 2969.25 is No. 24AP-553 6

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Bluebook (online)
2025 Ohio 1033, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-wolfe-v-ohio-dept-of-rehab-corr-ohioctapp-2025.