Christian v. Davis

Summary

The Supreme Court of Ohio affirmed the dismissal of Wayne Christian’s habeas corpus petition. The court held that his equal-protection and due-process challenges to R.C. 2903.11(B)(3) were nonjurisdictional claims for which habeas corpus was unavailable because adequate remedies existed through direct appeal or postconviction relief. The court concluded that the trial court had subject-matter and personal jurisdiction over Christian.

Holdings

1. Habeas corpus does not lie for nonjurisdictional equal-protection, due-process, or cruel-and-unusual-punishment claims that could have been raised on direct appeal or through post-conviction relief.
2. A challenge to the trial court's exercise of jurisdiction is not a challenge to the court's subject-matter or personal jurisdiction; the alleged unconstitutionality of the criminal statute did not deprive the trial court of jurisdiction to sentence Christian.
3. The habeas petition was properly dismissed under Civ.R. 12(B)(6) because Christian could prove no set of facts entitling him to habeas relief and immediate release.

Questions Presented

1. Whether Christian's equal-protection, due-process, and cruel-and-unusual-punishment challenges to R.C. 2903.11(B)(3) were cognizable in habeas corpus.
2. Whether the alleged unconstitutionality of R.C. 2903.11(B)(3) deprived the trial court of jurisdiction to sentence Christian.
3. Whether the Eleventh District properly dismissed the habeas petition under Civ.R. 12(B)(6).

Disposition

affirmed