Robinson v. State

Summary

The Ninth District Court of Appeals of Ohio dismissed Martin Robinson’s petition for a writ of habeas corpus. The court held that Robinson, an incarcerated inmate seeking a filing-fee waiver, failed to satisfy the mandatory affidavit and account-balance requirements of Ohio Revised Code 2969.25(C)(1).

Holdings

1. An inmate's civil action against a government entity or employee must be dismissed when the inmate fails to comply with the mandatory filing requirements of R.C. 2969.25.
2. Substantial compliance does not satisfy R.C. 2969.25(C); an inmate must strictly adhere to the statutory requirements.

Questions Presented

1. Whether Robinson's habeas corpus action had to be dismissed because his affidavit of indigency failed to comply with the mandatory requirements of R.C. 2969.25(C)(1).
2. Whether substantial compliance with R.C. 2969.25(C) was sufficient to avoid dismissal.

Disposition

dismissed