Is Ohio's Execution Protocol Invalid Because It Didn't Go Through Rulemaking Process?
Cleveland Jackson v. State of Ohio et al., Case No. 2020-0676, and James D. O'Neal v. State of Ohio et al., Case No. 2020-0683
Tenth District Court of Appeals (Franklin County)
ISSUE: Is Ohio's execution protocol a rule subject to the formal rulemaking procedures of R.C. 111.15, making the protocol invalid for failing to comply with the statute?