This case began in 2010, when United States marshals had a warrant to arrest Rodney Williams. Acting on a reasonable belief that that they would find him at Yanko Mansaray’s house, the marshals entered and searched for Williams. Instead of Williams, they found a large quantity of ecstasy pills.
Based on this evidence – which Mansaray filed a motion to suppress at trial – Mansaray was convicted of a drug offense and a related offense and sentenced to 11 years in prison.
In late 2010, Mansaray’s convictions were reversed by the court of appeals, which concluded that the ecstasy pills found in his house should have been suppressed at trial. The court stated that the warrant issued for the arrest of Rodney Williams did not authorize the marshals to search Mansaray’s house. Mansaray was released on bond, and the charges against him were ultimately dismissed.
Mansaray subsequently filed a complaint asserting that he is a wrongfully imprisoned individual. If a person proves that he is a wrongfully imprisoned individual, then he may commence a civil action against the state in the court of claims to seek compensation.
The trial court dismissed Mansaray’s complaint, but the court of appeals reversed, concluding that Mansaray satisfied all five requirements called for in the law that deals with wrongful imprisonment. After that, his case came before us – the Ohio Supreme Court – for a final review.
Was Mansaray a “wrongfully imprisoned individual” as defined by the law? In a case from 2012, we established that a person who claims to be a wrongfully imprisoned individual must prove all five factors in the law by a preponderance of the evidence before seeking compensation from the state for wrongful imprisonment.
The first three factors simply establish that the individual was charged with a felony or aggravated felony, was found guilty, and sentenced to prison. The fourth factor a wrongfully imprisoned individual must prove is that the individual’s conviction was vacated, dismissed, or reversed on appeal, and no criminal proceeding is pending.
When Mansaray was in prison and filed his complaint, the wrongful imprisonment law set forth the fifth element of the definition as follows: “Subsequent to sentencing and during or subsequent to imprisonment, an error in procedure resulted in the individual’s release, or it was determined by a court of common pleas that the offense of which the individual was found guilty…either was not committed by the individual or was not committed by any person.”
The fifth factor may be fulfilled in one of two ways. The first way: subsequent to sentencing and during or subsequent to imprisonment “an error in procedure resulted in the individual’s release.” The second way: the charged offense “was not committed by the individual or no crime was committed at all (actual innocence).”
In this case, Mansaray did not allege a claim of actual innocence. Accordingly, we focused – as the court of appeals did – on the first method of satisfying the fifth factor.
The plain and ordinary meaning of the language in the law – “Subsequent to sentencing and during or subsequent to imprisonment, an error in procedure resulted in the individual’s release” – is clear and unambiguous. Nevertheless, the two sides in this case offered vastly different interpretations.
It’s obvious that to satisfy the fifth factor, something must happen subsequent to sentencing and imprisonment. The state’s version is that the subsequent event is an error in procedure that occurs after sentencing and during or after imprisonment. Mansaray’s version is that the subsequent event is a judicial determination that an error occurred, even if that error occurred prior to sentencing and imprisonment.
The state’s version is the meaning that is obvious and common in large part because in the state’s version, the introductory phrase modifies the phrase “error in procedure.”
In Mansaray’s version, the introductory phrase modifies a phrase that doesn’t even appear in the law: “a judicial determination that an error in procedure occurred.” When we interpret laws, we will not insert words unless it is absolutely necessary, which it isn’t in this case. Nothing in the language of the law suggests, even indirectly, that the subsequent event is a judicial determination that an error occurred.
Although Mansaray’s version may be consistent with a reasonable, or a possible legislative objective, it isn’t an objective that is apparent. Nothing in the law indicates that the Ohio legislature intended to open the state to liability for wrongful imprisonment when a conviction is reversed based on a procedural error that occurred prior to sentencing.
Mansaray’s interpretation would greatly expand the ability of defendants to seek compensation for wrongful imprisonment. If that is indeed what the legislature intended, it did a remarkable job of keeping that to itself – and it will be able to enact such legislation upon learning that we do not think that it has already done so.
Finally, one last flaw in Mansaray’s version is that the fifth factor of the law will always be satisfied when a defendant satisfies the first four factors. When a defendant who satisfies one through four is released from prison based on a determination that there has been an error in procedure, the determination will necessarily have occurred subsequent to sentencing and during or subsequent to imprisonment. We consider that to be an absurd result, which is to be avoided.
Although satisfying the fifth factor would not mean that a defendant is necessarily a wrongfully imprisoned individual – because a defendant would still have to satisfy factors one through four – Mansaray’s version would swallow the actual-innocence part of the provision, rendering it superfluous. Nothing in the wrongful imprisonment law suggests that the legislature intended that result.
We therefore concluded – by a seven-to-zero vote – that the error in procedure, if that is what led to Mansaray’s release from prison, did not occur subsequent to sentencing and during or subsequent to imprisonment. Accordingly, Mansaray did not satisfy the fifth factor, which means that he is not a wrongfully imprisoned individual. We thus reversed the judgment of the court of appeals.