Ohio Supreme Court

Sparks v. Frederick

December 3, 20252025 Ohio 5370

Summary

The Ohio Supreme Court affirmed the Court of Appeals’ dismissal of Sparks’s habeas petition because his affidavit of indigency failed to include the statutory six‑month inmate‑account balance required by R.C. 2969.25(C)(1). The Court held that strict compliance with the statute is mandatory and that the dismissal is without prejudice.