State ex rel. Quinn v. Rastatter

Summary

The Supreme Court of Ohio addressed a mandamus action seeking to compel a trial judge to rule on a postconviction-relief petition and motions concerning a new trial. The court denied the request as moot regarding the postconviction petition, granted a writ directing the judge to rule on the motion for leave to file a motion for a new trial, and denied relief regarding the accompanying new-trial motion because the motions must be addressed sequentially.

Holdings

1. A request for mandamus relief to compel a ruling on a postconviction-relief petition is moot when the trial court has already ruled on the petition.
2. To obtain a writ of mandamus, a relator must establish a clear legal right to the requested relief, a clear legal duty on the respondent to provide it, and the lack of an adequate remedy in the ordinary course of law.
3. When a defendant seeks leave to file a delayed motion for a new trial based on newly discovered evidence, the trial court must first rule on the motion for leave; the motion for a new trial may be considered only if leave is granted.
4. A trial court's approximately two-year failure to rule on a six-page motion for leave, considered under the totality of the circumstances, constitutes undue delay warranting mandamus relief.
5. The writ requires the trial judge to rule on the motion for leave but does not direct the judge how to decide it.

Questions Presented

1. Whether the request to compel a ruling on the postconviction-relief petition became moot after the trial court denied the petition.
2. Whether Quinn was entitled to mandamus relief compelling the trial judge to rule on his pending motion for leave to file a motion for a new trial.
3. Whether the trial judge could be compelled to rule on the included motion for a new trial before ruling on the motion for leave.
4. Whether the trial court's approximately two-year delay in ruling on the motion for leave was undue under the circumstances.

Disposition

writ_granted