State ex rel. Hayburn v. Kiefer

For a writ of quo warranto to issue, relator must show that he is entitled to the office of sheriff and that respondent is holding the office unlawfully. R.C. 2733.06; State ex rel. Wilson v. Gulvas (1992), 63 Ohio St.3d 600, 589 N.E.2d 1327; State ex rel. Delph v. Barr (1989), 44 Ohio St.3d 77, 541 N.E.2d 59, syllabus. Relator claims (1) that respondent failed to qualify as sheriff under R.C. 311.01(B)(8) (candidate or sheriff must have held, within three years prior to the “qualification date,” a “valid certificate of training as a law enforcement officer compensated with governmental…