Ohio Rev. Code » Chapter 2969
Ohio Revised Code

Ohio Rev. Code § 2969.25 (2026)

Affidavit of inmate of prior actions

✓ current as of May 2026
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Effective:
June 28, 2002
Latest Legislation:
Senate Bill 168 - 124th General Assembly
PDF:
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(A) At the time that an inmate commences a civil action or appeal against a government entity or employee, the inmate shall file with the court an affidavit that contains a description of each civil action or appeal of a civil action that the inmate has filed in the previous five years in any state or federal court. The affidavit shall include all of the following for each of those civil actions or appeals:

(1) A brief description of the nature of the civil action or appeal;

(2) The case name, case number, and the court in which the civil action or appeal was brought;

(3) The name of each party to the civil action or appeal;

(4) The outcome of the civil action or appeal, including whether the court dismissed the civil action or appeal as frivolous or malicious under state or federal law or rule of court, whether the court made an award against the inmate or the inmate's counsel of record for frivolous conduct under section 2323.51 of the Revised Code, another statute, or a rule of court, and, if the court so dismissed the action or appeal or made an award of that nature, the date of the final order affirming the dismissal or award.

(B) If an inmate who files a civil action in a court of common pleas, court of appeals, county court, or municipal court or an inmate who files an appeal from a judgment or order in a civil action in any of those courts has filed three or more civil actions or appeals of civil actions in a court of record in this state in the preceding twelve months or previously has been subject to the review procedure described in this division, the court may appoint a member of the bar to review the claim that is the basis of the civil action or the issues of law that are the basis of the appeal and to make a recommendation regarding whether the claim asserted in the action or the issues of law raised in the appeal are frivolous or malicious under section 2969.24 of the Revised Code, any other provision of law, or rule of court.

(C) If an inmate who files a civil action or appeal against a government entity or employee seeks a waiver of the prepayment of the full filing fees assessed by the court in which the action or appeal is filed, the inmate shall file with the complaint or notice of appeal an affidavit that the inmate is seeking a waiver of the prepayment of the court's full filing fees and an affidavit of indigency. The affidavit of waiver and the affidavit of indigency shall contain all of the following:

(1) A statement that sets forth the balance in the inmate account of the inmate for each of the preceding six months, as certified by the institutional cashier;

(2) A statement that sets forth all other cash and things of value owned by the inmate at that time.
Notes of Decisions
Cited in 746 cases (294 in the last 5 years), 1997–2026 · leading case: State ex rel. Parker Bey v. Ohio Bur. of Sentence Computation, 2021 Ohio 70 (Ohio Ct. App. 2021).
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State ex rel. Parker Bey v. Ohio Bur. of Sentence Computation, 2021 Ohio 70 (Ohio Ct. App. 2021). · cites it 37× “The magistrate determined that relator's failure to comply with the provisions of R.C. 2969.25 constitutes grounds for dismissal of the actions and has rec- ommended that this court grant the motion to dismiss filed in case No.”
State ex rel. Bey v. Bur. of Sentence Computation (Slip Opinion), 2022 Ohio 236 (Ohio 2022). · cites it 17× “] Mandamus—Inmate failed to comply with requirements of R.C. 2969.25(A)—Court of appeals’ dismissal of complaints affirmed.”
State ex rel. Walker v. Bolin, 2024 Ohio 5126 (Ohio 2024). · cites it 66× “However, he said the cashier completed Form 2257 instead, because the Attorney General’s Office had instructed cashiers at Ohio’s prisons to use only Form 2257, “knowing full well that the [Form] 2257 would be inadequate to satisfy the requirements of [R.C. 2969.25].” 2 January…”
State ex rel. Neil v. French (Slip Opinion), 2018 Ohio 2692 (Ohio 2018). · cites it 8× “Instead, Neil implies that he is seeking relief because the court's failure to serve the judgment properly cost him his opportunity to appeal. But Judge French agrees that he was not properly served with a decision and that Neil therefore "can proceed with an appeal of the trial…”
State ex rel. Roden v. Ohio Dept. of Rehab. & Corr. (Slip Opinion), 2020 Ohio 408 (Ohio 2020). · cites it 10× “3d 936 , ¶ 2 (“Noncompliance with the mandatory requirements of R.C. 2969.25 is fatal to a complaint for a writ of mandamus and warrants dismissal of the inmate’s action”).”
State ex rel. Armengau v. Ohio Dept. of Rehab. & Corr., 2017 Ohio 368 (Ohio Ct. App. 2017). · cites it 20× “{¶ 11} While Armengau has provided a certified cashier statement of his inmate account that complies with the requirements of R.”
State ex rel. Swanson v. Ohio Dept. of Rehab. & Corr. (Slip Opinion), 2019 Ohio 1271 (Ohio 2019). · cites it 7× “" Two weeks later, the magistrate issued a nunc pro tunc decision indicating that Swanson had failed to comply with R.C. 2969.25(A), not (C). 2018-Ohio-3761 , 2018 WL 4462215 , ¶ 14 and fn.”
Westerfield v. Bracy, 2023 Ohio 499 (Ohio 2023). · cites it 16× “] Habeas corpus—Inmate failed to comply with R.C. 2969.25(A)—Court of appeals’ judgment dismissing petition affirmed.”
State ex rel. Swopes v. McCormick, 2022 Ohio 4408 (Ohio 2022). · cites it 11× “15(C), means that if a plaintiff amends his complaint after the statute of limitations has expired, the statute of limitations will not bar the claims asserted in the amended pleading. See LaNeve v.”
State ex rel. Pointer v. Ohio Adult Parole Auth., 2022 Ohio 3261 (Ohio 2022). · cites it 26× “The magistrate further recommended denying Pointer’s motion for leave to amend his complaint because an R.C. 2969.25 defect “cannot be cured * * * by belatedly attempting to file a compliant affidavit.”
State ex rel. Hall v. Mohr (Slip Opinion), 2014 Ohio 3735 (Ohio 2014). · cites it 9× “{¶ 2} The matter was referred to a magistrate, who determined that Hall failed to file with his complaint several of the documents required by R.C. 2969.25. Specifically, he failed to file an affidavit of prior civil actions, required by R.”
State ex rel. Pointer v. Ohio Adult Parole Auth., 2022 Ohio 358 (Ohio Ct. App. 2022). · cites it 37× “Since compliance with the provisions of R.C. 2969.25 is mandatory, the magistrate recommends No.”
Show all 746 citing cases →
— Ohio Rev. Code § 2969.25(A) — 417 cases
State ex rel. Bey v. Bur. of Sentence Computation (Slip Opinion), 2022 Ohio 236 (Ohio 2022). “] Mandamus—Inmate failed to comply with requirements of R.C. 2969.25(A)—Court of appeals’ dismissal of complaints affirmed.”
State ex rel. Parker Bey v. Ohio Bur. of Sentence Computation, 2021 Ohio 70 (Ohio Ct. App. 2021). “The magistrate determined that relator's failure to comply with the provisions of R.C. 2969.25 constitutes grounds for dismissal of the actions and has rec- ommended that this court grant the motion to dismiss filed in case No.”
State ex rel. Swanson v. Ohio Dept. of Rehab. & Corr. (Slip Opinion), 2019 Ohio 1271 (Ohio 2019). “" Two weeks later, the magistrate issued a nunc pro tunc decision indicating that Swanson had failed to comply with R.C. 2969.25(A), not (C). 2018-Ohio-3761 , 2018 WL 4462215 , ¶ 14 and fn.”
Westerfield v. Bracy, 2023 Ohio 499 (Ohio 2023). “] Habeas corpus—Inmate failed to comply with R.C. 2969.25(A)—Court of appeals’ judgment dismissing petition affirmed.”
State ex rel. Pointer v. Ohio Adult Parole Auth., 2022 Ohio 3261 (Ohio 2022). “The magistrate further recommended denying Pointer’s motion for leave to amend his complaint because an R.C. 2969.25 defect “cannot be cured * * * by belatedly attempting to file a compliant affidavit.”
— Ohio Rev. Code § 2969.25(A)(1) — 80 cases
State ex rel. Parker Bey v. Ohio Bur. of Sentence Computation, 2021 Ohio 70 (Ohio Ct. App. 2021). “The magistrate determined that relator's failure to comply with the provisions of R.C. 2969.25 constitutes grounds for dismissal of the actions and has rec- ommended that this court grant the motion to dismiss filed in case No.”
State ex rel. Watkins v. Andrews, 29 N.E.3d 967 (Ohio 2015).
State ex rel. Ware v. Bur. of Sentence Computation, 2020 Ohio 2695 (Ohio Ct. App. 2020).
State ex rel. Bey v. Bur. of Sentence Computation (Slip Opinion), 2022 Ohio 236 (Ohio 2022). “] Mandamus—Inmate failed to comply with requirements of R.C. 2969.25(A)—Court of appeals’ dismissal of complaints affirmed.”
State ex rel. Ware v. Ohio Dept. of Rehab. & Corr., 2020 Ohio 594 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2969.25(A)(2) — 30 cases
State ex rel. Pointer v. Ohio Adult Parole Auth., 2022 Ohio 358 (Ohio Ct. App. 2022). “Since compliance with the provisions of R.C. 2969.25 is mandatory, the magistrate recommends No.”
Morris v. Keith, 2024 Ohio 1143 (Ohio Ct. App. 2024).
Hayes v. Baldwin, 2024 Ohio 2343 (Ohio Ct. App. 2024).
State ex rel. Ware v. Ohio Dept. of Rehab. & Corr., 2020 Ohio 594 (Ohio Ct. App. 2020).
State ex rel. Clay v. Galonski, 2024 Ohio 2985 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2969.25(A)(3) — 19 cases
Westerfield v. Bracy, 2023 Ohio 499 (Ohio 2023). “] Habeas corpus—Inmate failed to comply with R.C. 2969.25(A)—Court of appeals’ judgment dismissing petition affirmed.”
Morris v. Keith, 2024 Ohio 1143 (Ohio Ct. App. 2024).
State ex rel. Pointer v. Ohio Adult Parole Auth., 2022 Ohio 358 (Ohio Ct. App. 2022). “Since compliance with the provisions of R.C. 2969.25 is mandatory, the magistrate recommends No.”
State ex rel. Ware v. Byrd, 2022 Ohio 1175 (Ohio Ct. App. 2022).
State ex rel. Folley v. Foley, 2023 Ohio 4465 (Ohio Ct. App. 2023).
— Ohio Rev. Code § 2969.25(A)(4) — 22 cases
State ex rel. Ware v. Walsh (Slip Opinion), 2020 Ohio 769 (Ohio 2020).
State ex rel. Ware v. Ferrero, 2019 Ohio 3849 (Ohio Ct. App. 2019).
State ex rel. Ware v. Ohio Dept. of Rehab. & Corr., 2023 Ohio 3775 (Ohio Ct. App. 2023).
State ex rel. Ware v. Ohio Dept. of Rehab. & Corr., 2024 Ohio 47 (Ohio Ct. App. 2024).
Morris v. Keith, 2024 Ohio 1143 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2969.25(A)(C) — 1 case
Blackford v. Noble Corr. Inst., 2011 Ohio 3369 (Ohio Ct. App. 2011).
— Ohio Rev. Code § 2969.25(B) — 6 cases
State ex rel. Davic v. Franklin Cty. Court of Common Pleas, 2023 Ohio 1195 (Ohio Ct. App. 2023).
State of Ohio ex rel. Cleavenger v. O'Brien, 2020 Ohio 3010 (Ohio Ct. App. 2020).
State ex rel. Stokes v. Combs, 2025 Ohio 2132 (Ohio Ct. App. 2025).
Smith v. Buchanan, 2014 Ohio 359 (Ohio Ct. App. 2014).
Smith v. Buchanan, 2020 Ohio 3886 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2969.25(C) — 373 cases
State ex rel. Neil v. French (Slip Opinion), 2018 Ohio 2692 (Ohio 2018). “Instead, Neil implies that he is seeking relief because the court's failure to serve the judgment properly cost him his opportunity to appeal. But Judge French agrees that he was not properly served with a decision and that Neil therefore "can proceed with an appeal of the trial…”
State ex rel. Walker v. Bolin, 2024 Ohio 5126 (Ohio 2024). “However, he said the cashier completed Form 2257 instead, because the Attorney General’s Office had instructed cashiers at Ohio’s prisons to use only Form 2257, “knowing full well that the [Form] 2257 would be inadequate to satisfy the requirements of [R.C. 2969.25].” 2 January…”
State ex rel. Armengau v. Ohio Dept. of Rehab. & Corr., 2017 Ohio 368 (Ohio Ct. App. 2017). “{¶ 11} While Armengau has provided a certified cashier statement of his inmate account that complies with the requirements of R.”
State ex rel. Foster v. Foley, 2022 Ohio 3168 (Ohio 2022).
State ex rel. Swopes v. McCormick, 2022 Ohio 4408 (Ohio 2022). “15(C), means that if a plaintiff amends his complaint after the statute of limitations has expired, the statute of limitations will not bar the claims asserted in the amended pleading. See LaNeve v.”
— Ohio Rev. Code § 2969.25(C)(1) — 180 cases
State ex rel. Roden v. Ohio Dept. of Rehab. & Corr. (Slip Opinion), 2020 Ohio 408 (Ohio 2020). “3d 936 , ¶ 2 (“Noncompliance with the mandatory requirements of R.C. 2969.25 is fatal to a complaint for a writ of mandamus and warrants dismissal of the inmate’s action”).”
State ex rel. Walker v. Bolin, 2024 Ohio 5126 (Ohio 2024). “However, he said the cashier completed Form 2257 instead, because the Attorney General’s Office had instructed cashiers at Ohio’s prisons to use only Form 2257, “knowing full well that the [Form] 2257 would be inadequate to satisfy the requirements of [R.C. 2969.25].” 2 January…”
State ex rel. Ridenour v. Brunsman, 883 N.E.2d 438 (Ohio 2008).
State ex rel. Ware v. Bur. of Sentence Computation, 2020 Ohio 2695 (Ohio Ct. App. 2020).
State ex rel. Neil v. French (Slip Opinion), 2018 Ohio 2692 (Ohio 2018). “Instead, Neil implies that he is seeking relief because the court's failure to serve the judgment properly cost him his opportunity to appeal. But Judge French agrees that he was not properly served with a decision and that Neil therefore "can proceed with an appeal of the trial…”
— Ohio Rev. Code § 2969.25(C)(1)(2) — 1 case
State ex rel. Kimble v. Bur. of Sentence Computation, 2016 Ohio 7409 (Ohio Ct. App. 2016).
— Ohio Rev. Code § 2969.25(C)(2) — 16 cases
State ex rel. Armengau v. Ohio Dept. of Rehab. & Corr., 2017 Ohio 368 (Ohio Ct. App. 2017). “{¶ 11} While Armengau has provided a certified cashier statement of his inmate account that complies with the requirements of R.”
Robinson v. State (Slip Opinion), 2021 Ohio 3865 (Ohio 2021).
Anderson v. Monroe Cty. Common Pleas Court, 2023 Ohio 1343 (Ohio Ct. App. 2023).
State ex rel. Sajn v. Vogel, 2024 Ohio 1552 (Ohio Ct. App. 2024).
Johnson v. Robinson, 2016 Ohio 3366 (Ohio Ct. App. 2016).
— Ohio Rev. Code § 2969.25(c) — 1 case
State ex rel. Davis v. Holbrook, 2018 Ohio 3389 (Ohio Ct. App. 2018).
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