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State ex rel. Tilton v. Cornachio

2026-08-24

Summary

Holding. The court granted the respondents' motions to dismiss and dismissed the petition for writ of mandamus as moot, finding that the requested certified conviction document had been provided and that no legal duty existed to create a judicial accounting of sentencing materials beyond producing existing records.

Dennis Tilton filed a mandamus petition requesting that Judge Marisa Cornachio and prosecutor Jacqueline O'Donnell produce or identify the exact certified conviction document used at his sentencing hearing in municipal court. Tilton sought clarification about which specific document was presented to the court and whether it matched the certified Missouri DWI conviction that was later provided. The respondents argued they had no legal obligation to perform such an accounting because either they did not possess the document or no statute imposed such a duty.

The appellate court found that while Tilton originally sought a specific public record—the certified Missouri conviction—that document had been supplied by O'Donnell, making the petition moot as to the records request itself. The court determined that Tilton's additional demand for a 'judicial accounting' of the materials used at sentencing falls outside the scope of public records law and that Tilton identified no clear legal right or corresponding legal duty requiring the court to create such an accounting.

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

Key issues

  • Whether a judge or prosecutor must produce a specific certified conviction document used at sentencing
  • Whether mandamus lies to compel creation of a 'judicial accounting' of materials used at sentencing
  • When a public records mandamus petition becomes moot upon production of the requested document
  • Whether requests for judicial accounting fall within the scope of public records obligations

Procedural posture

Tilton filed an original action for writ of mandamus in the Ohio Court of Appeals challenging Judge Cornachio and prosecutor O'Donnell's failure to produce or identify the certified conviction document used at his sentencing hearing.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as State ex rel. Tilton v. Cornachio, 2026-Ohio-3299.]

IN THE COURT OF APPEALS OF OHIO

ELEVENTH APPELLATE DISTRICT

LAKE COUNTY

STATE OF OHIO ex rel. CASE NO. 2026-L-0053 DENNIS G. TILTON,

Relator, Original Action for Writ of Mandamus

- vs -JUDGE MARISA L. CORNACHIO,

et al.,

Respondents.

PER CURIAM OPINION AND JUDGMENT ENTRY

Decided: August 24, 2026

Judgment: Petition dismissed

Dennis G. Tilton, pro se, 35673 West Island Drive, Eastlake, OH 44095 (Relator).

Lisa M. Zaring and Cooper D. Bowen, Montgomery Jonson, L.L.P., 600 Vine Street, Suite 2650, Cincinnati, OH 45202 (For Respondent, Judge Marisa L. Cornachio).

Joseph R. Klammer, The Klammer Law Office, Ltd., 7482 Center Street, Unit 6, Mentor, OH 44060 (For Respondent, Jacqueline M. O’Donnell).

PER CURIAM.

{¶1} Relator, Dennis G. Tilton, filed a Petition for Writ of Mandamus against

Respondents, Judge Marisa L. Cornachio and Jacqueline M. O’Donnell. Relator’s Petition

sought a writ ordering Respondents “to produce or identify with specificity the exact

certified conviction document used” at Relator’s sentencing in the Willoughby Municipal

Court. He requested that Respondents “produce and attach a true and accurate copy of the exact certified conviction document referenced at sentencing and handed to the court

on January 14, 2025.”

{¶2} On June 3, 2026, O’Donnell filed a Motion to Deny as Moot and Motion for

Leave to Answer. O’Donnell’s Motion attached “the certified entry” referenced during

Relator’s sentencing. The attached document was a certified copy of Relator’s March 6,

2014, conviction for DWI in the 29th Judicial Circuit Court, Jasper County Missouri.

{¶3} On June 11, 2026, Relator filed an Opposition to the Motion to Deny as

Moot because O’Donnell did not answer the central issue raised in his petition, namely,

to produce the “exact sentencing document that the prosecutor represented to the court

as a certified conviction and that the court later stated was handed up.”

{¶4} On June 15, 2026, Judge Cornachio filed a Motion to Dismiss in which she

argued that she had no clear legal duty to provide the requested record to Relator

because she did not have any responsive record “in her custody or control.”

{¶5} On June 17, 2026, O’Donnell filed a Motion to Dismiss and Deny as Moot

on Question of “Identification” and an Answer. The Motion to Dismiss argued that no Ohio

statute created a duty requiring an Ohio prosecutor to identify a document used during a

sentencing hearing.

{¶6} On July 7, 2026, Relator filed a Brief in Opposition to Respondent

Cornachio’s Motion to Dismiss. Relator argued that a specific document was provided to

Judge Cornachio and that she had a legal duty to disclose what that document was and

whether it was in fact the “later produced” Missouri judgment of conviction. He argued

that the “issue is not whether a later-produced record exists in general form, but whether

the sentencing-use materials have been produced or otherwise accounted for with

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specificity.” Relator, in short, sought “a judicial accounting of the materials the court relied

upon” at his sentencing hearing and “whether the court can identify or account for the

materials used.” Based on this, he argued that the issue of mootness was not resolved

by O’Donnell’s production of a certified conviction or Judge Cornachio’s claim that she

did not possess the document.

{¶7} “Dismissal of an action seeking writs of mandamus, prohibition, and/or

procedendo under Civ.R. 12(B)(6) is appropriate if we find that after presuming all factual

allegations in the complaint as true and drawing all reasonable inferences in the relator’s

favor, it appears beyond doubt that the relator can prove no set of facts entitling him to

relief.” State ex rel. Gordon v. Summit Cty. Court of Common Pleas, 2025-Ohio-2927, ¶

8. “While we must accept factual assertions as true, ‘unsupported legal conclusions, even

when cast as factual assertions, are not presumed true for purposes of a motion to

dismiss.’” Id., quoting State ex rel. Matre v. Reed, 2020-Ohio-4777, ¶ 12. “We may

consider documents attached to or incorporated into the complaint when ruling on a

Civ.R. 12(B)(6) motion to dismiss.” Id. “A court is not required to accept allegations in a

complaint as true when they are contradicted by documents attached to the complaint.”

State ex rel. Washington v. D’Apolito, 2018-Ohio-5135, ¶ 10.

{¶8} “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. “‘The

function of mandamus is to compel the performance of a present existing duty as to which

there is a default.’” State ex rel. Willis v. Sheboy, 6 Ohio St.3d 167, 168 (1983), quoting

State ex rel. Fed. Homes Properties, Inc. v. Singer, 9 Ohio St.2d 95, 96 (1967). “To be

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entitled to a writ of mandamus, a party must establish, by clear and convincing evidence,

(1) a clear legal right to the requested relief, (2) a clear legal duty on the part of the

respondent to provide it, and (3) the lack of an adequate remedy in the ordinary course

of the law.” State ex rel. Gadell-Newton v. Husted, 2018-Ohio-1854, ¶ 6.

{¶9} “The Public Records Act requires a custodian of public records to make

records available when properly requested.” State ex rel. Ames v. Big Walnut Local

School Dist. Bd. of Edn., 2025-Ohio-2493, ¶ 9, citing R.C. 149.43(B)(1). “When a records

custodian fails to fulfill this duty or any of the related duties set forth in the statute, the

requesting party may petition for a writ of mandamus to enforce its legal right of access

to the record.” Id., citing R.C. 149.43(C)(1)(b). “A public office is under no duty to create

new documents to satisfy a public-records request.” State ex rel. McDougald v. Greene,

2020-Ohio-5100, ¶ 10. “It necessarily follows that when a requester seeks a nonexistent

record, a public office has no duty to provide it.” Id. “In general, a public-records

mandamus case becomes moot when the public office provides the requested records.”

State ex rel. Martin v. Greene, 2019-Ohio-1827, ¶ 7.

{¶10} Relator’s Petition sought a specific public record, to wit: the certified copy

of his Missouri DWI conviction. He has received it. However, Relator has argued that his

Petition is not moot because he is also seeking “a judicial accounting of the materials the

court relied upon” at his sentencing hearing and “whether the court can identify or account

for the materials used.”

{¶11} However, this relief does not fall within the ambit of a public records request,

and Appellant has not identified any clear legal right to this accounting. Nor has he

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identified any legal duty imposed on Respondents which would require Respondents to

affirmatively create such an accounting.

{¶12} O’Donnell has affirmatively provided a certified copy of the document

Relator has requested. Because of this, Relator’s Petition is now moot.

{¶13} For the foregoing reasons, Respondents’ Motions to Dismiss are granted,

and Relator’s Petition is dismissed. Any other pending motions are hereby overruled as

moot.

MATT LYNCH, P.J., JOHN J. EKLUND, J., ROBERT J. PATTON, J., concur.

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JUDGMENT ENTRY

For the reasons stated in the Per Curiam Opinion of this court, Respondents’

Motions to Dismiss are granted, and Relator’s Petition is dismissed.

Costs are taxed against Relator.

Any other pending motions are hereby overruled as moot.

PRESIDING JUDGE MATT LYNCH,

concurs

JUDGE JOHN J. EKLUND,

concurs

JUDGE ROBERT J. PATTON,

concurs

THIS DOCUMENT CONSTITUTES A FINAL JUDGMENT ENTRY

A certified copy of this opinion and judgment entry shall constitute the mandate

pursuant to Rule 27 of the Ohio Rules of Appellate Procedure.

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