Case Details
- Judge(s)
- Myers
- Status
- Published
- Procedural Posture
- appeal
Related Laws
No specific laws identified for this ruling.
Claim Types
Outcome
The appellate court affirmed the trial court's judgment in favor of the State of Ohio, holding that McClain had no constitutional or statutory right to a jury trial in his wrongful-imprisonment action and that the bench trial was properly conducted.
Excerpt
JURY TRIAL – R.C. 2743.48 – WRONGFUL IMPRISONMENT: R.C. 2743.48 does not provide a statutory right to a jury trial for the initial determination of innocence by the common pleas court in an action filed under R.C. 2743.48(B)(1). Because a wrongful-imprisonment action under R.C. 2743.48 is a special proceeding that did not exist at common law, R.C. 2311.04 does not provide a right to a jury trial for such an action. The application of R.C. 2721.10 is limited to actions brought under R.C. Chapter 2721 and does not provide a right to a jury trial in a wrongful-imprisonment action under R.C. 2743.48. Article I, Section 5 of the Ohio Constitution does not preserve a right to a jury trial for a wrongful-imprisonment action filed against the state because the action did not exist at common law. [But see DISSENT: A wrongful-imprisonment claim under R.C. 2743.48 functions as a modern, statutory extension of the common-law tort of false imprisonment, and this is enough to satisfy Ohio's "type of claim" standard for a jury trial right further, R.C. 2743.48 recognizes a cause of action to recover money damages, a classic form of legal relief that justifies a jury trial.]
Similar Rulings
Facing something similar at work?
Court rulings like this one are useful, but every situation is different. Take 2 minutes to see which laws may protect you — it's free, private, and no account is required to start.
This ruling information is sourced from public court records via CourtListener.com. It is provided for informational and educational purposes only and does not constitute legal advice.