Justia Ohio Supreme Court Opinion Summaries

In June 2017, a man killed his friend and her two adult daughters in their home. After purchasing weapons and related items, he arranged to visit the home when the daughters were away, but they returned during his visit. He assaulted the mother, then restrained all three women using threats and physical restraints. He proceeded to stab the mother, smother one daughter, and strangle the other, causing all of their deaths. The next day, their bodies were discovered after concerned friends and family entered the home. The suspect was located several days later after a police standoff, subsequently confessed, and was arrested.The case was first heard in the Cuyahoga County Court of Common Pleas, where a three-judge panel accepted the defendant’s guilty plea to multiple counts of aggravated murder, aggravated burglary, kidnapping, and gross abuse of a corpse. After a mitigation hearing, the panel sentenced him to death for each victim. On appeal, the Supreme Court of Ohio vacated the convictions and sentences, finding that the defendant had not been properly advised of certain constitutional rights during his plea. The case was remanded for new proceedings. Upon remand, the defendant again pleaded guilty before a new three-judge panel, which found him guilty and again imposed three death sentences after a mitigation hearing.The Supreme Court of Ohio reviewed the case as a matter of right. The defendant raised numerous legal issues, including claims regarding the weighing of aggravating and mitigating factors, the sufficiency of the indictment, the plea and jury waiver processes, the admission of evidence, and the constitutionality of Ohio’s death penalty scheme. The court overruled all claims. It held that the aggravating circumstances outweighed the mitigating factors beyond a reasonable doubt for each murder and that the death sentences were appropriate and proportionate to similar cases. The convictions and death sentences were affirmed. View "State v. Brinkman" on Justia Law

Six wind farms located in Minnesota, North Dakota, South Dakota, and Iowa, all subsidiaries of Avangrid Renewables, sought certification from the Public Utilities Commission of Ohio (PUCO) to be recognized as eligible Ohio renewable-energy-resource-generating facilities. Such certification would allow these out-of-state wind farms to sell renewable energy in Ohio. Carbon Solutions Group, L.L.C. (CSG), representing Ohio-based renewable energy interests, opposed the applications, arguing that the applicants failed to demonstrate their energy was physically deliverable into Ohio as required by state law.PUCO conducted a three-day evidentiary hearing in December 2022, during which staff, the applicants, CSG, and other interested parties presented testimony and evidence. The central issue was whether the energy generated by these noncontiguous out-of-state facilities could be shown to be deliverable into Ohio. The commission relied on its established Koda test, which uses distribution-factor (DFAX) power-flow studies conducted by regional transmission organizations (RTOs) to determine whether a facility’s energy is physically deliverable into Ohio. After review, PUCO found that the applicants’ DFAX studies, performed by PJM Interconnection, met the required deliverability thresholds and approved all six applications.CSG appealed to the Supreme Court of Ohio, arguing that the evidence was insufficient and that procedural errors occurred, including denial of a subpoena and improper reliance on hearsay. The Supreme Court of Ohio found that PUCO’s order was supported by sufficient evidence and complied with statutory requirements for findings and reasoning. The court held that the commission’s use of the Koda test and reliance on the PJM DFAX studies was reasonable and not against the manifest weight of the evidence or contrary to law. The court also found that CSG’s procedural objections were either waived or jurisdictionally barred. The Supreme Court of Ohio affirmed PUCO’s order. View "In re Application of Moraine Wind, L.L.C." on Justia Law

A federally chartered savings bank headquartered in Pennsylvania operated branches in Ohio and several other states. Ohio taxes financial institutions through a regressive-rate structure, where the tax rate decreases as a bank’s Ohio business increases. The bank claimed that Ohio’s tax scheme forced it to pay more taxes than a bank of similar size operating solely within Ohio, arguing this was unconstitutional discrimination against interstate commerce.The bank filed refund claims with the Ohio tax commissioner for multiple years, asserting the tax was unconstitutional. The tax commissioner denied the request, stating that administrative agencies lack authority to rule on the constitutionality of statutes. The bank then appealed to the Ohio Board of Tax Appeals, which also declined to address the constitutional claim and affirmed the denial of a refund.The Supreme Court of Ohio reviewed the case to determine whether Ohio’s financial-institutions tax violated the dormant Commerce Clause of the United States Constitution. The court applied the internal consistency test, which asks whether identical application of a tax scheme by every state would place interstate commerce at a disadvantage or result in double taxation. The court found that Ohio’s tax only applies to the portion of a bank’s equity capital attributable to its Ohio business and would not result in double taxation if every state adopted a similar scheme. The court also determined that the tax does not discriminate against interstate commerce, as it applies evenhandedly to both intrastate and interstate banks based solely on their Ohio business activity. The court rejected the bank’s arguments and requests for statutory modification, concluding that the tax scheme was constitutional and affirming the decision of the Board of Tax Appeals. View "Dollar Bank, FSB v. Harris" on Justia Law

A worker was severely injured while operating a piece of agricultural machinery at his place of employment. The machine’s power take-off (PTO) shaft, which should have been equipped with safety guards, lacked those guards at the time of the accident. The worker alleged that the absence of these safety guards was due to his employer’s deliberate removal, and that this action directly caused his injuries. He sued his employer for an intentional tort under Ohio law, specifically invoking a statutory provision that creates a rebuttable presumption of intent to injure when an employer deliberately removes an equipment safety guard and an injury results.The Madison County Court of Common Pleas denied the employer’s motion for summary judgment, finding a genuine dispute of material fact as to whether the employer had deliberately removed the safety guard. The case proceeded to trial, where the jury heard evidence about the condition of the machinery, the employer’s repair practices, and the employer’s responses to safety concerns. The jury found in favor of the worker, awarding significant compensatory damages for his injuries. On appeal, the Twelfth District Court of Appeals reversed, holding that the evidence did not support a finding of deliberate removal as a matter of law, and that the statutory presumption did not apply unless the employer both removed the guard and made a conscious decision not to replace it.The Supreme Court of Ohio reversed the judgment of the court of appeals. It held that when reviewing the denial of summary judgment after a trial, appellate courts must consider the full trial record, not just the pretrial record. The court further held that the statutory presumption applies when there is evidence of deliberate removal of a safety guard, and that courts may not require proof of a separate, additional decision not to replace the guard. The case was remanded for further proceedings consistent with this holding. View "Camara v. Gill Dairy, L.L.C." on Justia Law

A church with property insurance sustained windstorm damage and submitted a claim to its insurer. When the parties could not agree on the amount of loss, the church invoked the insurance policy’s binding appraisal process. Each party selected an appraiser, and the appraisers agreed on an award, which the insurer paid and the church accepted. Afterward, the church alleged it discovered additional, previously hidden damages, and the insurer refused to pay more than the appraisal award. The church then sued, claiming breach of contract and seeking to set aside the binding appraisal based on the later-discovered damage.The Franklin County Court of Common Pleas granted judgment on the pleadings to the insurer, finding that the appraisal award was binding and there was no evidence of fraud, misfeasance, or mistake to justify reopening the award. The Tenth District Court of Appeals reversed, holding that the church’s complaint pleaded mistake with sufficient particularity to satisfy Ohio’s Civil Rule 9(B), which requires that mistake be pled with particularity.The Supreme Court of Ohio reviewed the case and held that a binding appraisal award may only be set aside for fraud or manifest mistake, defined as an egregious error undermining the intent of the agreement, not a mere error in judgment. The court further concluded that, to plead mistake with particularity under Civil Rule 9(B), the facts alleged must satisfy the elements of mistake. Since the church only alleged that additional, hidden damages were discovered after the appraisal, and did not plead facts constituting a manifest mistake by the appraisers, the complaint did not state a claim for mistake. The Supreme Court of Ohio reversed the Tenth District’s judgment and reinstated the trial court’s dismissal of the complaint. View "One Church v. Bhd. Mut. Ins. Co." on Justia Law

A theft victim sought restitution from the person who broke into her office and stole property. The offender pleaded guilty to attempted breaking and entering and petty theft. At sentencing, the trial court did not award restitution, despite a request from the victim and supporting documentation. The victim initially filed a timely direct appeal, arguing for restitution under Marsy’s Law, which provides victims certain rights, including restitution. However, while her appeal was pending, she voluntarily dismissed it. Several years later, after related proceedings—including a writ of mandamus directing the trial court to determine restitution—the victim attempted to file a delayed appeal challenging the lack of restitution.After the victim’s direct appeal was dismissed, she sought mandamus relief in the Eighth District Court of Appeals, which partially granted her request by directing the trial court to consider restitution. The trial court scheduled a restitution hearing, but the offender appealed, and the Eighth District vacated the order for a hearing, holding the victim had forfeited the right to challenge restitution by dismissing her earlier appeal. The Supreme Court of Ohio declined jurisdiction over the victim’s appeal from that decision. The victim then moved for leave to file a delayed appeal of the original sentencing order, but the Eighth District denied her request, citing Appellate Rule 5(A), which allows delayed appeals only for defendants, not victims.The Supreme Court of Ohio held that victims seeking to appeal a trial court’s denial of restitution are subject to the procedural requirements of Appellate Rule 4(A) and Appellate Rule 5(A). The court concluded that neither the Ohio nor United States Constitutions require courts to allow victims to file delayed appeals, and that Appellate Rule 5(A)’s limitation to criminal defendants is valid. The judgment of the Eighth District was affirmed, and the victim’s motion for leave to file a delayed appeal was denied. View "State v. Barnes" on Justia Law

A homeowners association challenged an order issued by a joint board of county commissioners from Licking and Franklin Counties, which directed the Franklin County Engineer to prepare reports and plans for a proposed improvement of Cole Ditch, a waterway affecting both counties. The association alleged procedural deficiencies, including lack of notice to all affected landowners, and claimed that its rights were violated during the first hearing on the improvement petition. The engineer’s preliminary report found the improvement feasible and beneficial, but most landowners opposed it. The joint board nonetheless found the improvement necessary and ordered the project to move forward.The association appealed the joint board’s order in both the Licking County and Franklin County Courts of Common Pleas. Both courts dismissed the appeals. On further appeal, the Fifth District Court of Appeals held that the Licking County court was not required to convene a joint panel of judges, that the association had no right to appeal the order after the first hearing, and that the matter was not ripe for review. In contrast, the Tenth District Court of Appeals reversed the Franklin County dismissal, holding that a joint panel of judges should have been convened and that the association had standing and statutory authority to appeal. The Tenth District remanded for further proceedings, and certified a conflict with the Fifth District’s ruling.The Supreme Court of Ohio reviewed the case, affirming the Tenth District’s judgment. It held that any appeal from an order of a joint board of county commissioners not involving compensation or damages must be heard by a panel of judges from each affected county. It further held that any affected landowner, including a homeowners association whose procedural rights were allegedly violated, has standing and statutory authority to appeal any order issued after a first hearing. The Supreme Court affirmed and remanded for the joint panel to hear the appeal. View "Colt's Neck Homeowners Assn. v. Franklin Cty. Bd. of Commrs." on Justia Law

A man was convicted of aggravated murder and related offenses and sentenced to life imprisonment with the possibility of parole after 31 years. His convictions were affirmed by the Eighth District Court of Appeals, and the Supreme Court of Ohio declined to review them further. Several years later, he applied for postconviction DNA testing under Ohio law, seeking to have certain DNA evidence tested and uploaded to a database. The trial court denied this application, stating only that the defendant had not shown that DNA testing would be outcome determinative and that the results would not be probative.The Eighth District Court of Appeals reversed the trial court’s denial, holding that the trial court’s failure to provide an explanation for rejecting the application was contrary to law and constituted an abuse of discretion. The appellate court remanded the case to the trial court with instructions to state its analysis for its conclusion. Because it found the trial court’s order statutorily deficient, the appellate court did not address whether the trial court had abused its discretion in finding that DNA testing would not be outcome determinative.The Supreme Court of Ohio reviewed the case to decide what constitutes sufficient explanation by a trial court under R.C. 2953.73(D), which requires an order to state the reasons for accepting or rejecting a postconviction DNA testing application. The Supreme Court of Ohio held that a trial court satisfies this requirement when it provides a statutory reason for its decision, such as stating that DNA testing would not be outcome determinative. The Court reversed the appellate court’s judgment and remanded the case for the Eighth District Court of Appeals to review the trial court’s rejection of the application for abuse of discretion. View "State v. Lash" on Justia Law

Nelson Reillo was indicted in Cuyahoga County for two counts of rape and one count of gross sexual imposition, all stemming from allegations made by E.C., who was eight years old at the time of the alleged offenses. At trial, E.C. testified in detail regarding two incidents of abuse she attributed to Reillo, who was her mother’s boyfriend and living with her family then. E.C. described one incident involving oral contact and another involving physical contact while Reillo was partially unclothed. Additional testimony was presented by a social worker, a physician’s assistant, and a police detective, all relating to E.C.’s disclosures of abuse in later years. The jury found Reillo guilty on one count of rape and one count of gross sexual imposition, but acquitted him on the second rape charge.Reillo appealed to the Eighth District Court of Appeals, arguing that his convictions were against the manifest weight of the evidence and that the evidence was insufficient to support the gross sexual imposition conviction. The Eighth District reversed both convictions, holding that E.C.’s testimony lacked credibility due to inconsistencies and lack of detail, and that the appellate court could substitute its own judgment for that of the jury regarding E.C.’s credibility. The court described its role as that of a “thirteenth juror” and conducted a de novo review of the evidence, ultimately remanding the case for a new trial.The Supreme Court of Ohio reviewed the case and held that when conducting a manifest-weight review, an appellate court must defer to the fact-finder’s determinations regarding witness credibility, and may only disturb a conviction if the evidence is so heavily against it as to constitute a manifest miscarriage of justice. The Court concluded that the Eighth District erred by failing to defer to the jury’s credibility findings and by applying an improper de novo review. The Supreme Court of Ohio reversed the Eighth District’s judgment and remanded for consideration of the remaining assignment of error. View "State v. Reillo" on Justia Law

The case centers on a defendant who fired multiple shots over a public road toward a moving vehicle after seeing his car being driven away, allegedly stolen. The indictment charged him with two offenses: felonious assault and discharge of a firearm on or near prohibited premises. The latter charge was elevated from a misdemeanor to a third-degree felony because the indictment stated the conduct created a substantial risk of physical harm to a person or caused serious physical harm to property. During trial, evidence and instructions focused on this elevating element, and the defendant claimed self-defense.Following a mistrial in the first attempt, a jury in the Franklin County Court of Common Pleas convicted the defendant of the firearm discharge offense, using a verdict form that stated he was guilty “as charged in the indictment,” but did not specify the degree of the offense or recite the elevating element. The trial court sentenced him for a third-degree felony. The defendant did not object to the verdict form or to being sentenced for a felony. On appeal, the Tenth District Court of Appeals held that the verdict form’s omission required entry of conviction only for the lowest degree of the offense—a misdemeanor—and vacated the felony conviction, remanding for resentencing. The appellate court also rejected the defendant’s argument that he was entitled to a “stand your ground” jury instruction, as the conduct occurred before the amendment’s effective date.The Supreme Court of Ohio reviewed the case. It held that the “stand your ground” amendment does not apply retroactively to offenses committed before its effective date. The court further held that, although the verdict form did not comply with the statutory requirement to specify the offense’s degree or the elevating element, the defendant’s failure to object limited relief to plain-error review. The court found no plain error because the circumstances made clear the jury intended to convict on the elevated felony. The judgment was affirmed in part, reversed in part, and remanded. View "State v. Khalif" on Justia Law