IN THE COURT OF APPEALS OF OHIO
    TENTH APPELLATE DISTRICT
    Anthony Thompson,
    :
    Plaintiff-Appellant,
    :
    v.
    No. 00AP-331
    :
    Margarette Ghee,
    (ACCELERATED CALENDAR)
    :
    Defendant-Appellee.
    :
    D E C I S I O N
    Rendered on September 12, 2000
    Anthony Thompson, pro se .
    Betty D. Montgomery, Attorney General, and J. Eric Holloway,
    for appellee.
    APPEAL from the Franklin County Court of Common Ple as.
    BROWN, J.
    Anthony Thompson, plaintiff-appellant, appeals a j udgment of the Franklin
    County Court of Common Pleas granting a motion for
    summary judgment in favor of
    Margarette Ghee, defendant-appellee.
    Appellant is confined at the Chillicothe Correctio nal Institution. While
    confined, a panel of the Ohio Adult Parole Authorit y ("OAPA") granted appellant parole on
    or after July 27, 1998, contingent upon his complet ing a counseling program. The victims'
    families were notified of OAPA's decision, and appe llee issued a "stop letter" after the

    No. 00AP-331
    8
    Office of Victims Services petitioned the OAPA boar d for a hearing. On October 16,
    1998, the full OAPA board held a hearing on the mat ter, and, thereafter, a majority of the
    OAPA board determined that appellant's parole date should be June 5, 2003.
    On April 30, 1999, appellant filed an action seeki ng declaratory, injunctive,
    and monetary relief against appellee, the chairpers on of the OAPA. Appellant claimed in
    his complaint that the OAPA violated the ex post fa cto and equal protection clauses of the
    Ohio and United States Constitutions in denying him parole because they used the parole
    guidelines that were currently in effect rather tha n the guidelines in effect at the time he
    was originally sentenced.
    On June 4, 1999, appellee filed a motion to dismis s appellant's complaint
    pursuant to Civ.R. 12(B)(1) and 12(B)(6). On July
    13, 1999, the trial court granted
    appellee's motion to dismiss the action as it perta ined to monetary damages but denied
    the motion in all other respects. On February 4, 20 00, appellee filed a motion for
    summary judgment on the declaratory and injunctive claims. On February 29, 2000, the
    trial court granted appellee's motion for summary j udgment, noting that the motion was
    unopposed. On March 6, 2000, appellant filed a resp onse to appellee's motion for
    summary judgment. Appellant filed a motion to recon sider on March 8, 2000, which the
    trial court denied. Appellant now appeals the Febru ary 29, 2000 judgment of the trial
    court, asserting the following assignments of error :
    [1.] THE TRIAL COURT ERRED IN GRANTING MOTION
    FOR SUMMARY JUDGMENT IN FAVOR OF DEFENDANT
    WITHOUT ALLOWING FULL 28-DAY PERIOD AFTER

    No. 00AP-331
    8
    SERVICE OF MOTION IN WHICH TO SET DATE FOR NON-
    ORAL HEARING AS ALLOWED BY LOCAL RULE, OR
    INFORMING PLAINTIFF THAT LIMITATION TIME SET
    FORTH IN LOCAL RULE WOULD BE SHORTENED.
    [2.] THE TRIAL COURT ERRED BY GRANTING SUMMARY
    JUDGMENT TO DEFENDANT WHERE THERE EXISTED A
    GENUINE ISSUE OF EX POST FACTO VIOLATION,
    WHERE A NEW LEGAL CONDITION AND CRITERIA FOR
    PAROLE RELEASE CONSIDERATION WAS APPLIED TO
    APPELLANT AFTER THE GRANTING OF PAROLE.
    [3.] OHIO'S NEW BINDING PAROLE GUIDELINES ARE
    UNCONSTITUTIONAL
    AND
    UNENFORCEABLE
    ON
    GROUND[S] THAT THEY WERE PROMULGATED BY
    BODY TO WHICH LEGISLATURES, CONSISTENT WITH
    THE
    OHIO
    CONSTITUTION
    AND
    UNITED
    STATES
    CONSTITUTION, COULD NOT OR DID NOT DELEGATE
    THE TASK OF FIXING CRIMINAL PENALTIES FOR
    VIOLATION OF STATE LAW, AS THOSE VIOLATIONS
    RELATES [sic] TO PRE-SB 2 PRISONERS, WHEN SUCH
    GUIDELINES
    EXCEEDS
    [ sic]
    THE
    MAXIMUM
    PUNISHMENT/PENALTIES PRESCRIBED UNDER SB 2.
    Appellant argues in his first assignment of error
    that he was precluded from
    responding to the motion for summary judgment becau se the trial court granted the
    summary judgment before the expiration of twenty-ei ght days as required by Loc.R.
    57.01. Loc.R. 57.01 provides, in pertinent part:
    All motions for summary judgment filed pursuant to Civil Rule
    56 are hereby set for a non-oral hearing date on th e 28
    th
    day
    following the filing of the motion for summary judg ment.
    Motions shall be deemed submitted to the judge for
    non-oral
    hearing on that date.
    Any party seeking to change
    the
    hearing date must do so by entry signed by the Tria l Judge
    and served on all counsel.
    This rule does not alte r the
    response dates for memorandum contra and replies un der
    Local Rule 21.01 ***.

    No. 00AP-331
    8
    Loc.R. 21.01 provides:
    *** The opposing counsel or a party shall serve any
    answer
    brief on or before the 14
    th
    day after the date of service as set
    forth on the certificate of service attached to the
    served copy
    of the motion. *** On the 28
    th
    day after the motion is filed, the
    motion shall be deemed submitted to the Trial Judge .
    In the present case, the certificate of service on
    appellee's motion for
    summary judgment indicated that it was served upon
    appellant on February 4, 2000.
    Thus, including the three additional days for maili ng pursuant to Civ.R. 6(E), appellant
    had until February 21, to file his responsive brief . However, he did not file such brief until
    March 6, 2000. Loc.R. 57.01 specifically states tha t its provisions do not alter the
    fourteen-day response time for memoranda contra und er Loc.R. 21.01. Therefore,
    appellant failed to file a timely responsive brief.
    However, appellant also asserts that because only
    twenty-five days –
    instead of twenty-eight days – elapsed between the
    date the motion was filed and the
    date of the trial court's decision, he "was not pro vided any opportunity to defend the
    motion other than motion in opposition. For exampl e, [appellant] would have asked [for]
    leave to attend Oral Hearing as provided under Loc. R. 21.01." Thus, appellant seems to
    be arguing that because the trial court issued the
    decision three days earlier than
    specified in Loc.R. 57.01, he was deprived of the o pportunity to file certain pleadings
    during those three days.
    However, appellant's argument hinges on a hypothet ical situation that
    clearly did not take place. Appellant's argument is
    insincere in that he claims he was

    No. 00AP-331
    8
    prejudiced by the trial court issuing the judgment three days early. The twenty-eighth day
    after submission of the motion for summary judgment was March 3, 2000. Appellant could
    not have been prevented from filing any pleadings b efore that time because he could not
    have been aware of the trial court's judgment until he received it on March 2 or 3, at the
    earliest. Therefore, even if the trial court would have not have issued its decision until the
    twenty-eighth day, on March 3, the record is clear
    that appellant failed to submit any
    motion or other pleading by that date. Simply, appe llant did not file any timely pleadings
    with regard to appellee's motion for summary judgme nt and cannot argue now that
    hypothetically he "could have" but for the trial co urt's actions. Thus, any error by the trial
    court in rendering a decision before the expiration of twenty-eight days pursuant to Loc.R.
    21.01 and 57.01 was harmless error. Appellant's fir st assignment of error is overruled.
    Before addressing the remaining assignments of er ror, we must address
    another issue. It is a fundamental tenet that a par ty who does not respond to an adverse
    party's motion for summary judgment may not raise i ssues on appeal that should have
    been raised in response to the motion for summary j udgment. Maust v. Meyers Products,
    Inc. (1989), 64 Ohio App.3d 310, 313-314; Haas v. Indus. Comm. (Dec 21, 1999),
    Franklin App. No. 99AP-475, unreported; Bradley v. Kijauskus (Mar. 26, 1998); Bank
    One, Columbus, N.A. v. Adams (Mar. 18, 1993), Franklin App. No. 92AP-1413,
    unreported. Thus, because appellant failed to file a timely response to appellee's motion
    for summary judgment, he should be precluded from r aising the remaining arguments.
    We also note that appellant's third assignment of e rror raises two additional grounds –

    No. 00AP-331
    8
    nondelegation of authority and separation of powers – that he failed to present in any
    meaningful or timely manner below. As such, these a rguments should also be deemed
    waived for appellate purposes. State v. Stojetz (1999), 84 Ohio St.3d 452, 455. However,
    despite these deficiencies, in the interests of jus tice, we will address the argument
    contained in appellant's assignment of error number two and three with regard to ex post
    facto prohibition, which appellant raised below and was the gravamen of his complaint.
    Appellant argues in his second assignment of error that the trial court erred
    in granting summary judgment because there remained a genuine issue of material fact
    as to whether the OAPA's use of different guideline s, than were in place at the time of his
    original parole hearing, violated the ex post facto
    prohibition of the United States
    Constitution. He argues in his third assignment of error that the trial court erred in failing
    to find that a genuine issue of material fact remai ned as to whether the OAPA's use of
    parole guidelines, in general, violates the ex post facto clause. Pursuant to Civ.R. 56,
    summary judgment is appropriate when there remains no genuine issue of material fact,
    and, when construing the evidence most strongly in
    favor of the non-moving party,
    reasonable minds can only conclude that the moving
    party is entitled to judgment as a
    matter of law. Zivich v. Mentor Soccer Club, Inc. (1998), 82 Ohio St.3d 367, 369-370.
    "When reviewing a trial court’s ruling on summary j udgment, the court of appeals
    conducts an independent review of the record and st ands in the shoes of the trial court."
    Mergenthal v. Star Banc Corp. (1997), 122 Ohio App.3d 100, 103.

    No. 00AP-331
    8
    Under R.C. 2967.03, the parole decision is discre tionary. State ex rel. Blake
    v. Shoemaker (1983), 4 Ohio St.3d 42; State ex rel. Ferguson v. Ohio Adult Parole Auth.
    (1989), 45 Ohio St.3d 355. The OAPA's use of intern al guidelines does not alter the
    decision's discretionary nature. State ex rel. Hattie v. Goldhardt (1994), 69 Ohio St.3d
    123, 125. Because neither statute nor regulation cr eated the guidelines, and the board
    need not follow them, they place no "substantive li mits on official discretion," and
    appellant cannot claim any right to have any partic ular set of guidelines apply. Olim v.
    Wakinekona (1983), 461 U.S. 238, 239, 103 S.Ct. 1741, 1747. W e have specifically held
    that a prisoner has no right to rely on the parole
    guidelines in effect prior to his parole
    hearing date, and, thus, any application of amended
    parole guidelines are not
    retroactively applied ex post facto. State v. Caslin (Sept. 29, 1998), Franklin App. No.
    98AP-463, unreported. Therefore, appellant was depr ived of no protected liberty interest
    when the OAPA used different guidelines than were e ffective during his original parole
    hearing, and he can claim no due process rights wit h respect to the parole determination.
    See Jago v. Van Curen (1981), 454 U.S. 14, 20-21, 102 S.Ct. 31, 35.
    Further, as the trial court pointed out, the Unit ed States District Court for the
    Southern District of Ohio has held that the parole
    guidelines are not violative of ex post
    facto prohibition, stating:
    *** [C]hanges in the parole matrix or parole guidel ines may
    constitutionally be applied to inmates even though
    the
    changes occur after the inmates entered the state p rison
    system. As the Court noted in its previous opinion
    and order,
    parole is a discretionary decision, and a state may
    constitutionally add or delete factors which guide the Parole

    No. 00AP-331
    8
    Board's exercise of its discretion without running afoul of the
    Constitution. Simply put, an inmate has no vested i nterest in
    any particular set of parole guidelines, regulation s, or matrices
    which assist the Parole Board in exercising its dis cretion, and
    changes in those matters do not impair any rights e njoyed by
    state prisoners pursuant to the United States Const itution.
    Akbar-El v. Wilkinson (S.D. Ohio 1998), unreported, affirmed
    (C.A. 6, 1999), 181 F.3d 99.
    We also note that appellant states a fourth assign ment of error in his
    statement of facts. However, this assignment of err or is not referenced elsewhere, and he
    fails to present any argument regarding this assign ment of error. Therefore, we decline to
    address it. See App.R. 12(A)(2).
    For the reasons set forth above, we find that the
    trial court did not err in
    granting appellee's motion for summary judgment. A ppellant's three assignments of error
    are overruled, and the judgment of the Franklin Cou nty Court of Common Pleas is
    affirmed.
    Judgment affirmed.
    TYACK and DESHLER, JJ., concur.
    _____________________

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