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Ohio Revised Code

Ohio Rev. Code § 2969.21 (2026)

Civil actions by inmate against governmental entity or employee definitions

✓ current as of May 2026
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Effective:
March 22, 2019
Latest Legislation:
House Bill 411 - 132nd General Assembly
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As used in sections 2969.21 to 2969.27 of the Revised Code:

(A) "Clerk" means the elected or appointed clerk of any court in this state, except the court of claims or the supreme court, in which an inmate has commenced a civil action against a government entity or employee or has filed an appeal of the judgment or order in a civil action of that nature.

(B)(1) "Civil action or appeal against a government entity or employee" means any of the following:

(a) A civil action that an inmate commences against the state, a political subdivision, or an employee of the state or a political subdivision in a court of common pleas, court of appeals, county court, or municipal court;

(b) An appeal of the judgment or order in a civil action of the type described in division (B)(1)(a) of this section that an inmate files in a court of appeals.

(2) "Civil action or appeal against a governmental entity or employee" does not include any civil action that an inmate commences against the state, a political subdivision, or an employee of the state or a political subdivision in the court of claims or the supreme court or an appeal of the judgment or order entered by the court of claims in a civil action of that nature, that an inmate files in a court of appeals or the supreme court.

(C) "Employee" means an officer or employee of the state or of a political subdivision who is acting under color of state law.

(D) "Inmate" means a person who is in actual confinement in a state correctional institution or in a county, multicounty, municipal, municipal-county, or multicounty-municipal jail or workhouse or a releasee who is serving a sanction in a violation sanction center.

(E) "Inmate account" means an account maintained by the department of rehabilitation and correction under rules adopted by the director of rehabilitation and correction pursuant to section 5120.01 of the Revised Code or a similar account maintained by a sheriff or any other administrator of a jail or workhouse or by the administrator of a violation sanction center.

(F) "Political subdivision" means a county, township, city, or village; the office of an elected officer of a county, township, city, or village; or a department, board, office, commission, agency, institution, or other instrumentality of a county, township, city, or village.

(G) "State" has the same meaning as in section 2743.01 of the Revised Code.

(H) "State correctional institution" has the same meaning as in section 2967.01 of the Revised Code.

(I) "Violation sanction center" means a prison that houses releasees who have violated a post-release control sanction or the terms and conditions of parole or of a conditional pardon and that is operated pursuant to section 2967.141 of the Revised Code.
Notes of Decisions
Cited in 151 cases (89 in the last 5 years), 1997–2026 · leading case: Fuqua v. Williams, 100 Ohio St. 3d 211 (Ohio 2003).
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Fuqua v. Williams, 100 Ohio St. 3d 211 (Ohio 2003). · cites it 5× “The provisions in R.C. 2969.21 through 2969.27 were enacted as part of Sub.”
In Re Robinson, 292 B.R. 599 (Bankr. S.D. Ohio 2003). · cites it 4× “66(A)(12)(c) of the Ohio Revised Code provides: Except in cases in which the person who receives the payment is an inmate, as defined in section 2969.21 of the Revised Code, and in which the payment resulted from a civil action or appeal against a government entity or employee,…”
State ex rel. Swanson v. Ohio Dept. of Rehab. & Corr. (Slip Opinion), 2019 Ohio 1271 (Ohio 2019). “" R.C. 2969.21(B)(1)(a). Because this action originated in the court of appeals, it is subject to the terms of R.”
State ex rel. Ware v. Ohio Dept. of Rehab. & Corr., 2024 Ohio 1015 (Ohio 2024). · cites it 2× “See id; R.C. 2969.21(B)(1)(a). So one has to wonder: Does 21 SUPREME COURT OF OHIO Ware claim indigent status in this court, but not in the courts of appeals, because he may do so here without providing an affidavit showing the balance of his inmate account? {¶ 63} Ware has made…”
DeVore v. Black (Slip Opinion), 2021 Ohio 3153 (Ohio 2021). · cites it 3× “” R.C. 2969.21(B)(1)(a) defines the phrase “civil action or appeal against a government entity or employee” to include a “civil action that an inmate commences against the state, a political subdivision, or an employee of the state or a political subdivision in a court of common…”
The State Ex Rel. McDougald v. Greene., 2018 Ohio 4200 (Ohio 2018). · cites it 2× “" That phrase is defined in R.C. 2969.21(B) as follows: (1) "Civil action or appeal against a government entity or employee" means any of the following: (a) A civil action that an inmate commences against the state, a political subdivision, or an employee of the state or a…”
Hayes v. Baldwin, 2024 Ohio 2343 (Ohio Ct. App. 2024). · cites it 9× “See Fuqua at paragraph one of the syllabus (“A habeas corpus action is a civil action and therefore the provisions of R.C. 2969.21 through 2969.27 are applicable to such action.”
State ex rel. Evans v. Tieman (Slip Opinion), 2019 Ohio 2411 (Ohio 2019). · cites it 2× “Those rules impose no special filing requirements on inmates seeking writs of mandamus.”
State ex rel. McGrath v. McDonnell, 2010 Ohio 4726 (Ohio 2010). “25 applies to his mandamus complaint because he is an inmate, 1 and his mandamus case is a *512 civil case for purposes of R.C. 2969.21(B)(1)(a), which addresses inmate actions against government entities.”
Hawkins v. S. Ohio Corr. Facility, 809 N.E.2d 1145 (Ohio 2004). “2d 982 , syllabus (“A habeas corpus action is a civil action and therefore the provisions of R.C. 2969.21 through 2969.27 are applicable to such action”).”
State ex rel. Swain v. Adult Parole Auth. (Slip Opinion), 2017 Ohio 9175 (Ohio 2017). “See also R.C. 2969.21(B). R.C. 2969.25(C) requires an inmate seeking a waiver of the applicable filing fee to submit with his complaint an affidavit of indigency and “[a] statement that sets forth the balance in the inmate account of the inmate for each of the preceding six…”
State ex rel. Berry v. Booth, 2024 Ohio 5774 (Ohio 2024). · cites it 2× “R.C. 2969.21(B)(2); State ex rel. McDougald v.”
Show all 151 citing cases →
— Ohio Rev. Code § 2969.21(B) — 9 cases
State ex rel. Swain v. Adult Parole Auth. (Slip Opinion), 2017 Ohio 9175 (Ohio 2017). “See also R.C. 2969.21(B). R.C. 2969.25(C) requires an inmate seeking a waiver of the applicable filing fee to submit with his complaint an affidavit of indigency and “[a] statement that sets forth the balance in the inmate account of the inmate for each of the preceding six…”
The State Ex Rel. McDougald v. Greene., 2018 Ohio 4200 (Ohio 2018). “" That phrase is defined in R.C. 2969.21(B) as follows: (1) "Civil action or appeal against a government entity or employee" means any of the following: (a) A civil action that an inmate commences against the state, a political subdivision, or an employee of the state or a…”
Hayes v. Baldwin, 2024 Ohio 2343 (Ohio Ct. App. 2024). “See Fuqua at paragraph one of the syllabus (“A habeas corpus action is a civil action and therefore the provisions of R.C. 2969.21 through 2969.27 are applicable to such action.”
State ex rel. Sherrills v. Clerk of Courts, 750 N.E.2d 594 (Ohio 2001).
State ex rel. Sherrills v. Franklin Cty. Clerk of Courts, 2001 Ohio 211 (Ohio 2001).
— Ohio Rev. Code § 2969.21(B)(1) — 5 cases
State ex rel. Bey v. Loomis (Slip Opinion), 2021 Ohio 2066 (Ohio 2021).
State ex rel. Rush v. Ohio State Emp. Relations Bd., 2024 Ohio 5787 (Ohio Ct. App. 2024).
State ex rel. Williams v. Ohio Adult Parole Auth., 2025 Ohio 1939 (Ohio Ct. App. 2025).
State ex rel. Robinson v. Chambers-Smith, 2024 Ohio 2347 (Ohio Ct. App. 2024).
State ex rel. Dews v. Dept. of Rehab. & Corr., Bur. of Sentence Computation, 2024 Ohio 3259 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2969.21(B)(1)(a) — 15 cases
State ex rel. Swanson v. Ohio Dept. of Rehab. & Corr. (Slip Opinion), 2019 Ohio 1271 (Ohio 2019). “" R.C. 2969.21(B)(1)(a). Because this action originated in the court of appeals, it is subject to the terms of R.”
State ex rel. Ware v. Ohio Dept. of Rehab. & Corr., 2024 Ohio 1015 (Ohio 2024). “See id; R.C. 2969.21(B)(1)(a). So one has to wonder: Does 21 SUPREME COURT OF OHIO Ware claim indigent status in this court, but not in the courts of appeals, because he may do so here without providing an affidavit showing the balance of his inmate account? {¶ 63} Ware has made…”
DeVore v. Black (Slip Opinion), 2021 Ohio 3153 (Ohio 2021). “” R.C. 2969.21(B)(1)(a) defines the phrase “civil action or appeal against a government entity or employee” to include a “civil action that an inmate commences against the state, a political subdivision, or an employee of the state or a political subdivision in a court of common…”
State ex rel. McGrath v. McDonnell, 2010 Ohio 4726 (Ohio 2010). “25 applies to his mandamus complaint because he is an inmate, 1 and his mandamus case is a *512 civil case for purposes of R.C. 2969.21(B)(1)(a), which addresses inmate actions against government entities.”
State ex rel. Evans v. Tieman (Slip Opinion), 2019 Ohio 2411 (Ohio 2019). “Those rules impose no special filing requirements on inmates seeking writs of mandamus.”
— Ohio Rev. Code § 2969.21(B)(2) — 12 cases
The State Ex Rel. McDougald v. Greene., 2018 Ohio 4200 (Ohio 2018). “" That phrase is defined in R.C. 2969.21(B) as follows: (1) "Civil action or appeal against a government entity or employee" means any of the following: (a) A civil action that an inmate commences against the state, a political subdivision, or an employee of the state or a…”
State ex rel. Berry v. Booth, 2024 Ohio 5774 (Ohio 2024). “R.C. 2969.21(B)(2); State ex rel. McDougald v.”
State ex rel. Evans v. Tieman (Slip Opinion), 2019 Ohio 2411 (Ohio 2019). “Those rules impose no special filing requirements on inmates seeking writs of mandamus.”
DeVore v. Black (Slip Opinion), 2021 Ohio 3153 (Ohio 2021). “” R.C. 2969.21(B)(1)(a) defines the phrase “civil action or appeal against a government entity or employee” to include a “civil action that an inmate commences against the state, a political subdivision, or an employee of the state or a political subdivision in a court of common…”
The State Ex Rel. Martin v. Greene., 2018 Ohio 4201 (Ohio 2018).
— Ohio Rev. Code § 2969.21(C) — 88 cases
State of Ohio ex rel. Cleavenger v. O'Brien, 2020 Ohio 3010 (Ohio Ct. App. 2020).
State ex rel. Guyton v. Jones, 2021 Ohio 430 (Ohio Ct. App. 2021).
Stewart v. Corrigan, 97 Ohio St. 3d 80 (Ohio 2002).
State ex rel. Gordon v. Summit Cty. Court of Common Pleas, 2023 Ohio 4107 (Ohio Ct. App. 2023).
Stewart v. Corrigan, 2002 Ohio 5316 (Ohio 2002).
— Ohio Rev. Code § 2969.21(C)(1) — 1 case
State ex rel. Yantis v. Dept. of Rehab. & Corr., 2017 Ohio 8590 (Ohio Ct. App. 2017).
— Ohio Rev. Code § 2969.21(D) — 9 cases
Hayes v. Baldwin, 2024 Ohio 2343 (Ohio Ct. App. 2024). “See Fuqua at paragraph one of the syllabus (“A habeas corpus action is a civil action and therefore the provisions of R.C. 2969.21 through 2969.27 are applicable to such action.”
State ex rel. McGrath v. Ohio Adult Parole Auth., 100 Ohio St. 3d 72 (Ohio 2003).
State ex rel. Ware v. Ferrero, 2019 Ohio 3849 (Ohio Ct. App. 2019).
Perry v. Sweeney, 2020 Ohio 119 (Ohio Ct. App. 2020).
State ex rel. Wright v. Callahan, 2025 Ohio 2762 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2969.21(E) — 10 cases
State ex rel. Sajn v. Vogel, 2024 Ohio 1552 (Ohio Ct. App. 2024).
State ex rel. Robinson v. Page, 2024 Ohio 4468 (Ohio Ct. App. 2024).
State ex rel. Rush v. Ohio State Emp. Relations Bd., 2024 Ohio 5787 (Ohio Ct. App. 2024).
Hayes v. Baldwin, 2024 Ohio 928 (Ohio Ct. App. 2024).
State ex rel. Stevens v. Hoying, 2024 Ohio 1999 (Ohio Ct. App. 2024).
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