Johnson v. Madison Cty. Court of Common Pleas

Summary

The Supreme Court of Ohio affirmed dismissal of Ronald G. Johnson’s action seeking monetary damages for alleged false imprisonment. The court held that the Ohio Department of Rehabilitation and Correction, rather than the county common pleas court, was the proper defendant and that monetary-damages claims against the state must be filed in the Ohio Court of Claims.

Holdings

1. The state agency that calculates the prisoner's term and actually confines the prisoner, rather than the common pleas court that imposed the sentence, is the proper party for a colorable false-imprisonment claim arising from the calculation of the confinement period.
2. A claim seeking monetary damages from the state must be filed in the Court of Claims, not in the court of appeals.

Questions Presented

1. Whether the Madison County Court of Common Pleas was the proper defendant for Johnson's claim that the state was falsely imprisoning him through an allegedly erroneous sentence computation.
2. Whether a claim seeking monetary damages from the state for false imprisonment must be filed in the Court of Claims rather than in a court of appeals.

Disposition

affirmed