State ex rel. Esch v. Lake County Board of Elections

We are asked to decide in this appeal if the title requirement in R.C. 731.31 must be met with strict compliance. For the reasons that follow, we hold that it must and, therefore, that the board of elections has a clear duty to reject the instant noncomplying petition. Moreover, because the board does not argue that Esch has a plain and adequate remedy at law, we further hold that the court of appeals properly granted Esch a writ of mandamus.

R.C. 731.31 provides, in pertinent part:

“Any initiative or referendum petition may be presented in separate parts, but each part of any initiative…