Whether petitioner was denied his Fourteenth Amendment due process right to a fair parole hearing

QUESTIONS PRESENTED FOR REVIEW 1. WHETHER PETITION WAS DENIED HIS FOURTEENTH AMENDMENT DUE PROCESS RIGHT TO A FAIR PAROLE HEARING WHERE THE PAROLE BOARD, DURING PAROLE CONSIDERATION, DETERMINED PETITIONER TO BE THE BIOLOGICAL FATHER OF THE CHILD BORN TO THE RAPE VICTIM, DENIED THE PETITIONER'S REQUEST FORA DNA BLOOD GROUPING-GENETIC TEST TO EITHER ESTABLISH OR REFUTE THE PATERNITY, RESPONDENTS DETERMINATION, THEN DENIED PAROLE BASED ON THE DETERMINATION THAT PETITIONER CAUSED THE VICTIM TO BECOME PREGNANT DUE TO THE RAPE; 2. WHETHER THE RESPONDENTS, OHIO DEPARTMENT OF REHABILITATION AND CORRECTIONS (“ODRC”), AND THE OHIO ADULT PAROLE AUTHORITY (OAPA”), IS REQUIRED BY LAW TO PROVIDE PETITIONER WITH A DNA BLOOD GROUPINGGENETIC TEST, UPON REQUEST, TO EITHER ESTABLISH OR REFUTE THE RESPONDENTS DETERMINATION THAT PETITIONER IS THE BIOLOGICAL FATHER OF THE CHILD BORN TO THE RAPE VICTIM; 3. WHETHER THE RESPONDENTS DENIAL OF A BLOOD GROUPING TESTS TO AN INDIGENT PATERNITY DEFENDANT, WHO IS UNABLE TO PREPAY FOR SUCH TESTS, AND WHO FACES THE STATE (OHIO PAROLE BOARD) AS AN ADVERSARY WHEN THE MOTHER IS ASSERTING THAT PETITIONER IS THE BIOLOGICAL FATHER, VIOLATES THE DUE PROCESS GUARANTEE OF THE FOURTEENTH AMENDMENT TO THE UNITED STATES CONSTITUTION AS SET FORTH IN Little v. Streater, 452 U.S. 1, 13-17, 68 L. Ed. 2d 627, 101 S. Ct. 2202 (1981); 4. WHERE THE RESPONDENT'S ODRC & OAPA DETERMINES THAT PETITIONER IS THE BIOLOGICAL FATHER OF THE CHILD, WHEN THERE HAS BEEN NO COURT ADJUDICATION, AND FOR THE PURPOSE OF DETERMINING PAROLE, DOESTHAT ESTABLISH ANY LEGAL RELATIONSHIP WITH THE RAMIFICATIONS OF IMPOSING OR CONFERRING ANY PARENTAL RIGHTS, PRIVILEGES, DUTIES, AND OBLIGATIONS? 5. WHETHER UNDER STATE OR FEDERAL LAW, WHEN THE PAROLE BOARD (STATE AGENCY) MADE THE DETERMINATION THAT PETITIONER IS THE BIOLOGICAL FATHER OF THE CHILD BORN TO THE RAPE VICTIM, AS PART OF THEIR DECISION PROCESS REGARDING PETITIONER’S PAROLE RELEASE CONSIDERATION, IS TANTAMOUNT TO LEGALLY ESTABLISHING THE PATERNITY OF THE CHILD BORN TO THE VICTIM? 6. WHETHER OHIO LAW, WHICH ALLOWS THE PAROLE BOARD TO MAKE PATERNITY DETERMINATION AS PART OF THEIR DECISION MAKING PROCESS REGARDING RELEASE CONSIDERATION ON PAROLE, EVEN WHERE THERE HAS BEEN NO PRIOR PATERNITY ADJUDICATION BY A COURT OF COMPETENT JURISDICTION, VIOLATES 2 THE DUE PROCESS AND EQUAL PROTECTION CLAUSES OF THE FOURTEENTH AMENDMENT? LIST OF ALL PARTIES 1. Ricardo Dodson, Petitioner , 2. Ohio Department of Rehabilitation & Corrections, Respondents, 3. Ohio Adult Parole Authority, Respondents, RELATED CASES State ex rel. Dodson v. Ohio Dep't of Rehab. & Corr., 2022-Ohio-2552, P1, 2022 Ohio App. LEXIS 2415, *1, 2022 WL 2951709 (Ohio Ct. App., Franklin County July 26, 2022); State ex rel. Dodson v. Ohio Dep't of Rehab. & Corr., 2023-Ohio-2263, 2023 Ohio LEXIS 1325 (Ohio, July 6, 2023); State ex rel. Dodson v. Ohio Dep't of Rehab. & Corr., 2023-Ohio-3169, 2023 Ohio LEXIS 1790 (Ohio, Sept. 12, 2023); . Dodson v. Mohr, 2018 U.S. Dist. LEXIS 160910, 2018 WL 4518018 (S.D. Ohio, Sept. 20, 2018). Dodson v. Mohr, 2021 U.S. District. LEXIS 30970, 2021 WL 664034 (S.D. Ohio, Feb. 19, 2021); State v. Dodson (Oct. 31, 1991), Franklin App. No. 91AP-498, 1991 Ohio App. LEXIS 5264; 3