On Tuesday, August 19, 2025, the Supreme Court of Ohio affirmed the Sixth District Court of Appeals’ dismissal of a mandamus complaint filed by Alfred A. Johnson Sr., an inmate at Toledo Correctional Institution.

Johnson sought a writ to compel Lucas County Common Pleas Court Judge Joseph McNamara to vacate his sentence in a criminal case, State v. Johnson, and to correct the trial record.

Johnson, representing himself, filed the mandamus action in July 2024 in the Sixth District Court of Appeals. He argued that Judge McNamara violated his constitutional right to self-representation by denying his request to proceed without counsel during his trial. Johnson cited a 1975 U.S. Supreme Court ruling that established a defendant’s right to self-representation when the decision is made voluntarily, knowingly, and intelligently. He claimed that the denial of this right stripped the trial court of both personal and subject-matter jurisdiction, rendering his sentence void.

Additionally, Johnson alleged that Judge McNamara erred by not excluding a juror with whom the judge was acquainted and had previously worked. He also challenged the validity of his indictment, asserting that it lacked the necessary intent element of “purposefully” and instead included only “knowingly,” which he argued further undermined the court’s jurisdiction. Johnson’s request to “fix the record” was not detailed in his complaint.

The Sixth District Court of Appeals dismissed Johnson’s complaint in August 2024 without prior notice, concluding that the trial court had jurisdiction to convict him and that he had an adequate legal remedy through direct appeal to challenge his conviction.

The court noted that Johnson had raised the self-representation issue in his direct appeal, which was unsuccessful. The appeals court also rejected his claims regarding the juror and the indictment, stating that neither issue affected the trial court’s jurisdiction.

The court found that any errors, such as failing to conduct further inquiry about the juror, did not negate the court’s authority to hear the case. Similarly, it determined that any defect in the indictment was a procedural issue, not a jurisdictional one, and that Johnson had waived such objections by not raising them timely.

In its per curiam opinion, the Ohio Supreme Court upheld the Sixth District’s decision. The court ruled that the Lucas County Court of Common Pleas had proper jurisdiction over Johnson’s criminal case, which involved a second-degree felony robbery charge. The court clarified that personal jurisdiction was established through lawful process, arrest, and arraignment, none of which were affected by Johnson’s claims. It also confirmed that the trial court had subject-matter jurisdiction over felony cases under Ohio law.

The Supreme Court further noted that Johnson’s arguments, including alleged violations of his right to counsel, ineffective assistance of counsel, and issues with the juror and indictment, did not impact the trial court’s jurisdiction.

The court emphasized that Johnson had the opportunity to challenge these issues through his direct appeal, which constituted an adequate remedy in the ordinary course of law.

A copy of the original filing can be found here.