State ex rel. Maloney v. Sherlock

{¶ 1} In July 2002, Elizabeth Sublette, the Director of the Mahoning County Office of Management and Budget, issued a memorandum to the county “departments,” including the Probate and Juvenile Divisions of the Mahoning County Court of Common Pleas. In the memorandum, Sublette forecast a general-fund revenue decrease of 18 percent to 20 percent for 2003 and advised these departments to “begin the process of reducing the cost of service.”

{¶ 2} In August 2002, Sublette sent the departments a second memorandum in which she specified that budget papers for 2003 would be sent to them within the…