Login | December 26, 2024
Appellate panel says state court lacked jurisdiction in prison case
KEITH ARNOLD
Special to the Legal News
Published: December 23, 2024
A Tenth District Court of Appeals panel upheld a ruling by the Ohio Court of Claims that the state court lacked jurisdiction to hear the claim brought by a Grafton Correctional Institution inmate.
The 3-0 Franklin County appellate panel affirmed the trial court’s determination that Lonnie Prather’s negligence complaint against the prison amounted to a challenge of the conditions of his confinement––a subject matter outside of the trial court’s jurisdiction.
The court’s scope includes claims against the state for money damages and appeals of the Ohio attorney general decisions for claims filed under the Victims of Crime Compensation Program, according to the Court of Claims website.
“Under Ohio law, the Court of Claims lacks subject-matter jurisdiction to consider claims arising from alleged violations of the U.S. Constitution,” Tenth District Judge David Leland wrote in the panel’s decision. “In this respect, inmate complaints regarding conditions of confinement are treated as claims arising under 42, 1983, U.S.C., and this court has consistently held that the Court of Claims does not have jurisdiction over 1983 actions.”
According to case background, Prather filed his complaint against the Ohio Department of Rehabilitation and Corrections (ODRC) June 2, 2023, after a prison employee caused the unnecessary delay of a document needed for the sale of real estate for which Prather had a third interest.
The inmate asserted that the inaction and conduct of the department and its employee resulted in a loss of thousands of dollars in the sale of the property and damages in the amount of $13,000.
Prather had first filed an electronic informal complaint resolution, which he said was closed by the Grafton warden Jan. 3, 2023.
He then escalated the matter, filing a grievance to the Grafton Inspector of Institutional Services, which investigated the matter and “granted” his grievance.
Prather filed a motion for summary judgment Oct. 16, 2023, and the department filed a response to the motion, as well as a cross-motion for summary judgment, Nov. 7, 2023, summary provided.
The Court of Claims granted the department’s motion for summary judgment May 3 holding that Prather’s claim ultimately amounted to a challenge regarding his conditions of confinement, and the court lacks jurisdiction over the matter.
The Court of Claims dismissed the man’s claim without prejudice.
On appeal, Prather argued that the trial court abused its discretion by recasting the prison’s admission of negligence and liability into a policy violation without providing a basis for a cause of action.
Additionally, he argued that the lower court ruling violated his right to due process of law.
“ODRC argues appellant assumes ODRC made an admission of negligence but that, as found by the Court of Claims, any violations of prison rules or policies do not equate to an admission of liability,” Leland wrote. “ODRC argues that, despite appellant’s assertion of negligence, the Court of Claims properly found the allegations of his complaint presented a challenge to the conditions of confinement. ODRC further maintains that, apart from alleging violation of prison rules or policy based on the prison’s internal grievance process, appellant offered no additional evidence demonstrating an actionable claim of negligence.”
He added having determined that the Court of Claims properly held the underlying nature of Prather’s claim involved a challenge to the conditions of his confinement, the appellate panel concluded that the trial court did not err in its grant of summary judgment in favor of ODRC and dismissing the action for lack of subject-matter jurisdiction.
Tenth District judges Betsy Luper Schuster and Carly Edelstein concurred with Leland’s opinion.
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