State ex rel. Sandy v. Spatny

Summary

The Supreme Court of Ohio denied Joseph Sandy’s request for a writ of mandamus compelling the warden of Grafton Correctional Institution to place him in an opioid-treatment program providing buprenorphine or methadone. The court held that Sandy failed to establish a clear legal right to treatment of his choice or a clear legal duty requiring the warden to provide it, and that he had an adequate remedy through a motion to enforce the trial court’s amended order.

Holdings

1. Sandy failed to establish by clear and convincing evidence that he had a clear legal right to placement in the K-12 opioid-treatment program or that the warden had a clear legal duty to provide buprenorphine or methadone rather than the clinically recommended naltrexone.
2. Sandy had an adequate remedy in the ordinary course of law, independently precluding mandamus relief.
3. The court denied the respondent's request to strike the unsigned statement of evidence because the failure to sign appeared inadvertent rather than an intentional attempt to defeat Civ.R. 11's purposes, and the respondent had addressed the merits.

Questions Presented

1. Whether Sandy established a clear legal right to placement in the K-12 opioid-treatment program for buprenorphine or methadone.
2. Whether the warden had a clear legal duty enforceable in mandamus to place Sandy in the K-12 program based on the trial court's orders.
3. Whether Sandy had an adequate remedy in the ordinary course of law that precluded mandamus relief.
4. Whether Sandy's unsigned evidentiary submission should be stricken under Civ.R. 11.

Disposition

writ_denied