The Ohio Supreme Court affirmed the Third District Court of Appeals' dismissal of an incarcerated inmate's mandamus complaint, reinforcing strict compliance requirements for prisoner litigation in *State ex rel. Martre v. North Central Correctional Complex* (2026-Ohio-162).
Derrick Martre, an inmate at the North Central Correctional Complex, filed a mandamus action against the prison and several departments within the facility. However, the court of appeals dismissed his complaint sua sponte after determining that his affidavit of indigency failed to comply with Ohio Revised Code Section 2969.25(C).
The case centers on R.C. 2969.25(C)(1), which requires inmates filing legal actions to submit a statement setting forth the balance in their inmate account for each of the preceding six months as certified by the institutional cashier. This requirement is part of Ohio's broader framework governing inmate litigation and is designed to prevent frivolous lawsuits while ensuring appropriate court access.
The Third District Court of Appeals dismissed Martre's complaint on its own motion, finding that his filing materials did not include the required certified account balance statement. This procedural deficiency rendered his complaint non-compliant with statutory filing requirements, leading to dismissal without consideration of the underlying merits.
Martre appealed the dismissal to the Ohio Supreme Court, challenging the court of appeals' decision to dismiss his complaint for the procedural failure. The appeal was submitted to the high court on October 28, 2025, and decided on January 22, 2026.
In a per curiam opinion joined by all seven justices—Chief Justice Kennedy and Justices Fischer, DeWine, Brunner, Deters, Hawkins, and Shanahan—the Ohio Supreme Court affirmed the lower court's dismissal. The unanimous decision reinforces the strict application of filing requirements for inmate litigation under Ohio law.
The court held that the court of appeals did not err in sua sponte dismissing Martre's complaint for failure to submit the required account balance statement. The decision emphasizes that procedural compliance is mandatory for inmate-initiated litigation, regardless of the potential merits of the underlying claims.
R.C. 2969.25(C)(1) serves multiple purposes within Ohio's legal framework. The statute helps courts screen inmate litigation by requiring disclosure of financial information that may indicate whether an inmate has sufficient funds to pay filing fees or other court costs. It also provides transparency about an inmate's financial status, which can be relevant to determining indigency status and fee waiver eligibility.
The requirement for institutional cashier certification adds an additional layer of verification, ensuring that the account balance information provided to the court is accurate and has been verified by prison financial personnel. This certification requirement helps prevent inmates from misrepresenting their financial status to avoid court costs or filing fees.
Mandamus actions are extraordinary writs that compel government officials or entities to perform mandatory duties. Inmates frequently use mandamus petitions to challenge prison policies, seek access to programs, or compel specific actions by correctional administrators. However, these actions must comply with all applicable filing requirements, including those specific to inmate litigation.
The dismissal in this case was sua sponte, meaning the court acted on its own initiative rather than in response to a motion by the opposing parties. Courts have authority to dismiss cases sua sponte when they identify fundamental procedural deficiencies that prevent proper adjudication of the matter.
The Ohio Supreme Court's affirmance sends a clear message about the importance of strict compliance with inmate litigation requirements. Courts will not overlook procedural deficiencies, even when inmates represent themselves pro se and may lack legal training or resources.
This decision is part of a broader trend in Ohio and other jurisdictions toward strict enforcement of prisoner litigation requirements. Such requirements are often justified as necessary to manage court dockets and prevent abuse of the judicial system, though critics argue they can create barriers to legitimate legal claims.
The case also highlights the challenges inmates face when attempting to navigate complex legal procedures without legal representation. While inmates have constitutional rights to court access, they must still comply with applicable procedural requirements to have their cases heard on the merits.
For correctional institutions and inmate advocates, the decision reinforces the importance of ensuring that inmates understand and comply with all filing requirements when pursuing legal action. Prison law libraries and legal assistance programs may need to provide additional guidance on these procedural requirements.
The ruling affects how Ohio courts will handle similar deficiencies in inmate filings going forward. Courts are likely to continue strictly enforcing R.C. 2969.25(C)(1) requirements, making proper documentation essential for any inmate seeking to pursue legal action against correctional institutions or officials.
Moving forward, inmates filing legal actions in Ohio must ensure they include all required documentation, including certified account balance statements, to avoid dismissal. The decision establishes clear precedent that procedural compliance cannot be overlooked, regardless of the underlying merits of inmate claims.