LAW.coLAW.co

State ex rel. Campbell v. Lucas Cty. Court of Common Pleas Clerk

2026-08-18

Summary

Holding. The Court of Appeals granted the respondent clerk's motion to dismiss Campbell's petition for writ of mandamus and dismissed the petition in its entirety, holding that Campbell had no clear legal right to or the respondent's clear legal duty to provide a second transcript where the state had already furnished one copy to his appellate counsel during his direct appeal and no subsequent appeal or post-conviction relief was pending.

Terry Jay Campbell sought a writ of mandamus to compel the Lucas County Court of Common Pleas Clerk to provide him with a copy of his trial transcript from a criminal case. Campbell acknowledged that the state had already provided a complete transcript to his appellate counsel for use in his direct appeal, but argued the clerk should furnish him a new copy because his counsel failed to deliver the original to him. The court rejected this request, finding that Campbell's right to a state-funded transcript existed only while an appeal or post-conviction proceeding was pending. Since Campbell's direct appeal had concluded and no post-conviction action was underway, he had no legally protected entitlement to an additional transcript.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Right to state-funded trial transcripts for indigent defendants
  • Scope of transcript provision limited to pending appeals or post-conviction proceedings
  • Whether mandamus was available when state fulfilled obligation to appellate counsel
  • Distinction between right to transcript and subsequent requests for additional copies

Procedural posture

Campbell petitioned for writ of mandamus pro se; the clerk moved to dismiss; Campbell failed to file a response.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as State ex rel. Campbell v. Lucas Cty. Court of Common Pleas Clerk, 2026-Ohio-3192.]

IN THE COURT OF APPEALS OF OHIO

SIXTH APPELLATE DISTRICT

LUCAS COUNTY

State ex rel. Terry Jay Campbell Court of Appeals No. L-26-00108

Relator

v.

Clerk of Court Lucas County Court DECISION AND JUDGMENT Of Common Pleas

Decided: August 18, 2026

Respondent

*****

Terry Jay Campbell, pro se.

Kevin A. Pituch and John A. Borell, for respondent.

*****

OSOWIK, P.J.

{¶ 1} This matter is before the court on respondent Clerk of Court, Lucas County

Court of Common Pleas’ motion to dismiss relator Terry Campbell’s petition for writ of

mandamus. In relator’s petition, he alleges that respondent has failed to provide him with a copy of his requested transcript in case No. CR0201603375, and requests this court to

compel respondent to produce a complete copy of the trial transcript.

{¶ 2} Respondent argues in its motion, that the petition should be dismissed

because (1) relator was provided with the transcript for use in his direct appeal in case

No. L-17-1289, and (2) relator has an adequate remedy at law.

{¶ 3} Relator has failed to file a response to the motion to dismiss.

{¶ 4} “Mandamus is a writ, issued in the name of the state to an inferior tribunal, a

corporation, board, or person, commanding the performance of an act which the law

specially enjoins as a duty resulting from an office, trust, or station.” R.C. 2731.01. To

be entitled to a writ of mandamus, relator must establish (1) a clear legal right to the

requested relief, (2) a clear legal duty on the part of respondent to provide that relief, and

(3) the lack of an adequate remedy in the ordinary course of the law. State ex rel. Waters

v. Spaeth, 2012-Ohio-69, ¶ 6; State ex rel. Harris v. Rhodes, 54 Ohio St.2d 41, 42 (1978).

The Ohio Supreme Court has recognized that “Civ.R. 12(B)(6) dismissals may be based

on ‘merits’ issues such as the availability of an adequate remedy in the ordinary course of

law.” State ex rel. Hummel v. Sadler, 2002-Ohio-3605, ¶ 20.

{¶ 5} The Supreme Court of Ohio has repeatedly confirmed that an indigent

defendant is entitled to one transcript upon appeal or in seeking post-conviction relief.

State ex rel. Murr v. Thierry, 34 Ohio St. 3d 45, 45-46 (1987), citing State ex rel. Partee

v. McMahon, 175 Ohio St. 243 (1963). However, that right is subject to certain limits—

one being that only one copy of a transcript need be provided to the defendant, id., citing

State ex rel. Vitoratos v. Walsh, 173 Ohio St. 467 (1962); see also State v. Crawford, 2007

2.

Ohio 2263, ¶ 8 (6th Dist.), citing State ex rel. Call v. Zimmers, 85 Ohio St. 3d 367, 368

(1999), and another is that an appeal or post-conviction action must be pending at the

time the transcript is sought, id., citing State ex rel. Partee; State ex rel. Catlino v. Clerk

of Courts, 9 Ohio St.2d 101 (1967); State ex rel. Clark v. Marshall, 63 Ohio St.2d 107,

(1980).

{¶ 6} Here, relator’s argument is not that the State never provided him with a copy

of his transcript—relator admits that he has already been provided with one transcript for

his direct appeal in case No. L-17-1289. (“A complete trial transcript was prepared at

state expense for purposes of that appeal [case No. L-17-1289]. … The transcript was

delivered to Relator’s appointed appellate counsel.”). What relator is really arguing is

that although the State provided the transcript to his appellate counsel, his counsel failed

to turn the transcript over to him, therefore, the State should provide him with a new

transcript.

{¶ 7} Accordingly, while relator had a clear legal right to a copy of his transcript

while his direct appeal was pending, the State fulfilled its duty when it provided relator’s

appellate counsel with a complete copy of relator’s transcript. Additionally, the record

does not indicate relator has a petition for post-conviction relief pending. Therefore,

relator has no clear legal right to the relief requested, nor does respondent have a clear

duty to provide such relief.

{¶ 8} For these reasons, we grant respondent’s motion, and we dismiss relator’s

petition in its entirety. Relator is responsible for the costs of this action. The clerk is

3.

directed to serve upon all parties, within three days, a copy of this decision in a manner

prescribed by Civ.R. 5(B).

{¶ 9} It is so ordered.

Thomas J. Osowik, P.J.

JUDGE

Christine E. Mayle, J.

JUDGE

Gene A. Zmuda, J.

CONCUR. JUDGE

This decision is subject to further editing by the Supreme Court of

Ohio’s Reporter of Decisions. Parties interested in viewing the final reported

version are advised to visit the Ohio Supreme Court’s web site at:

http://www.supremecourt.ohio.gov/ROD/docs/.

4.