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Wednesday, October 13, 2010

Supreme Court Rules Wrongful Imprisonment Claims May Not Originate in Ohio Court of Claims

Common Pleas Court Must First Find Claimant Was 'Wrongfully Imprisoned'

Griffith v. Cleveland, Slip Opinion No. 2010-Ohio-4905.
Franklin App. No. 08AP-964, 2009-Ohio-2854. Judgment of the court of appeals reversed.
Pfeifer, Lundberg Stratton, O'Connor, O'Donnell, Lanzinger, and Cupp, JJ., concur.
Brown, C.J., not participating.

(Oct. 12, 2010) The Supreme Court of Ohio held today that all wrongful-imprisonment claims brought against the state must follow a two-step process in which the claimant must first bring an action in a court of common pleas to secure a determination that he or she is a wrongfully imprisoned individual entitled to compensation, and then must file a civil action against the state in the Ohio Court of Claims to recover a sum of money.

The Court’s 6-0 decision, authored by Justice Paul E. Pfeifer, reversed a ruling by the 10th District Court of Appeals.

In 2003, the General Assembly amended R.C. 2743.48, the state law that authorizes persons who have been wrongfully imprisoned to recover civil damages from the state under certain circumstances. Among other changes, the 2003 amendment added language to the statute allowing recovery not only by persons who are officially exonerated of guilt for the crimes for which they were imprisoned, but also by persons whose convictions and prison sentences are vacated, dismissed or permanently overturned on appeal because of procedural errors during their trials.

In this case, Gerry Griffith Jr. of Cleveland was charged in federal district court with a firearms offense. Before trial, Griffith moved to suppress all evidence obtained through the search of his home, arguing that the search resulted from an unlawful arrest. The trial court denied the motion to suppress. Griffith was convicted on the firearms charge and sentenced to a prison term.

On review, the U.S. Sixth Circuit Court of Appeals ruled that Griffith’s arrest was unlawful, and the trial court should have suppressed the search results that yielded the evidence on which his conviction was based. On remand to the trial court, the firearms charge was dismissed and Griffith was released from custody.

Griffith filed a claim seeking damages from the state as a “wrongfully imprisoned individual” under R.C. 2743.48. Griffith filed his complaint directly with the Ohio Court of Claims. The state moved to dismiss the complaint, arguing that the Court of Claims did not have jurisdiction to consider a wrongful imprisonment claim until the claimant’s eligibility for damages had been certified by a common pleas court. The Court of Claims granted the motion to dismiss. On review, the 10th District Court of Appeals reversed the Court of Claims’ ruling and ordered it to accept and process Griffith’s complaint. In its opinion, the 10th District held that the 2003 amendments to R.C. 2743.48 did not impose a requirement of a prior common pleas judgment of eligibility for wrongful imprisonment claims that are based on procedural error.

The state sought and was granted Supreme Court review of the 10th District’s decision.

In today’s unanimous decision, Justice Pfeifer wrote: “Griffith argues, and we do not deny, that R.C. 2743.48(A), as amended, does not state that a claim premised on a procedural error must originate in a court of common pleas. It is equally clear, however, that the statute does not explicitly state that such a claim can originate in the Court of Claims. We consider the statute ambiguous as to the sole issue before us. Accordingly, we turn to other considerations to determine the intent of the General Assembly, as permitted by R.C. 1.49.”

“R.C. 1.49(D) permits a court, faced with determining the legislative intent behind an ambiguous statute, to consider ‘[t]he common law or former statutory provisions, including laws upon the same or similar subjects.’ … R.C. 2743.48(A) sets forth five requirements for a determination that a person is a wrongfully imprisoned individual. … Nothing in the statutory scheme states that the Court of Claims has authority to determine that a person is a wrongfully imprisoned individual. … R.C. 2743.48(H) states that to be eligible to recover compensation for wrongful imprisonment, a claimant ‘shall commence a civil action under this section in the court of claims no later than two years after the date of the entry of the determination of a court of common pleas that the individual is a wrongfully imprisoned individual.’ This provision also clearly authorizes a court of common pleas to determine that a person is a wrongfully imprisoned individual and just as clearly does not authorize the Court of Claims to make that determination.”

“Under R.C. 1.49(E), the intent of the legislature in enacting an ambiguous statute may be determined by considering ‘[t]he consequences of a particular construction.’ … If a wrongful-imprisonment case based on procedural error could originate in the Court of Claims, that court would have to rule on the criteria of R.C. 2743.48(A)(1) through (4). These criteria are replete with criminal-law considerations. The Court of Claims is statutorily designed to adjudicate civil claims and does not ordinarily address criminal issues. Further, if actions brought under R.C. 2743.48 could originate in the Court of Claims, attorneys and witnesses from the county of origin would all be required to travel to the Court of Claims in Franklin County. Nothing in the statutory scheme contemplates this waste of time and money.”

“…Based on the foregoing, we are convinced that the holding in Walden v. State … still applies: All wrongful-imprisonment claimants must follow a two-step process. In the first step, the claimant must bring an action in the court of common pleas to secure a determination that he or she is a wrongfully imprisoned individual entitled to compensation. In the second step, the claimant must file a civil action against the state, in the Court of Claims, to recover a sum of money. … We are further persuaded that the General Assembly intended that only courts of common pleas have jurisdiction to determine whether a person has satisfied the five requirements of R.C. 2743.48(A). Accordingly, only courts of common pleas can determine whether a person is a wrongfully imprisoned individual. We reverse the judgment of the court of appeals.”

Justice Pfeifer’s opinion was joined by Justices Evelyn Lundberg Stratton, Maureen O’Connor, Terrence O’Donnell, Judith Ann Lanzinger and Robert R. Cupp. Chief Justice Eric Brown did not participate in the court’s deliberations or decision in this case.

Benjamin C. Mizer, 614.466.8980, for the Ohio Attorney General's Office.

Charles W. Slicer, 937.223.1100, for Gerry Griffith Jr.

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