Robert Bates, an inmate at the Toledo Correctional Institution, sought to compel prison employee R. Copley to provide the names of two officers through a mandamus action under Ohio's Public Records Act. Bates had submitted two written requests, known as 'kites,' to the prison's business office in June 2025, seeking the names of officers he identified only by last name. When Copley, the business office supervisor, denied both requests, Bates filed his complaint in the Sixth District Court of Appeals seeking the officers' names, statutory damages, and court costs.
Writing for a unanimous court, the justices held that Ohio's inmate litigation statute requires 'strict compliance' and that Bates's affidavit was 'fatally deficient.' The court explained that 'an affidavit that fails to include each party to each prior civil action as required by R.C. 2969.25(A)(3) is therefore fatally deficient.' Bates had identified 16 civil cases he filed against government entities in the previous five years, but failed to list all defendants in several cases, including a 2022 federal civil rights action against '30 defendants in their individual capacities' where he named only two.
The court emphasized the mandatory nature of the statutory requirements, stating that 'R.C. 2969.25 is mandatory and requires strict compliance.' The justices noted that 'merely listing some parties (e.g., those mentioned in the case caption) does not constitute strict compliance,' citing previous precedent that dismissed cases for similar omissions.
The case reached the Ohio Supreme Court after the Sixth District Court of Appeals sua sponte dismissed Bates's complaint in September 2025. The appellate court had concluded that Bates failed to meet the procedural requirements of R.C. 2969.25(A), which mandates that inmates filing civil actions against government entities must provide detailed affidavits listing all prior litigation, including 'the name of each party' to each civil action filed in the previous five years.
Bates argued that the Sixth District had erred in dismissing his complaint, but the Supreme Court rejected this contention. The justices found that Bates 'failed to list the names of all defendants in three civil actions he had filed in the United States District Court for the Southern District of Ohio,' including cases with eight defendants and six defendants where he listed only six and one defendant respectively. The court concluded that 'the Sixth District did not err in concluding that Bates failed to strictly comply with R.C. 2969.25 or in sua sponte dismissing his complaint for that reason.'
The unanimous decision reflects Ohio courts' strict interpretation of inmate litigation requirements, continuing a line of cases that have dismissed prisoner lawsuits for technical non-compliance with affidavit requirements. The ruling reinforces that courts will not overlook procedural deficiencies even when inmates represent themselves pro se, as statutory compliance remains mandatory regardless of legal representation.
The court also denied Bates's motion for automatic reversal under Supreme Court Practice Rule 16.07(B) after the appellee failed to file a response brief. The justices explained that even when an opposing party doesn't respond, 'the appellant must demonstrate that he is reasonably entitled to reversal,' and Bates's brief did not 'reasonably appear to sustain reversal' given his clear statutory violations.