Justia Ohio Supreme Court Opinion Summaries

Elwood Jones was convicted by a Hamilton County jury of the aggravated felony murder, aggravated burglary, and aggravated robbery of Rhoda Nathan, and sentenced to death. At trial, evidence included the discovery of a pendant similar to Nathan’s in Jones’s vehicle and a hand injury Jones sustained on the day of the murder, which became infected with a bacteria consistent with a fist-to-mouth injury. Nathan’s tooth had been knocked out during the assault. Jones’s convictions and sentence were affirmed on direct appeal and postconviction relief was denied, including claims that the State suppressed material evidence in violation of Brady v. Maryland. Subsequent efforts for federal habeas corpus relief were also unsuccessful.In 2019, Jones moved for a new trial, citing newly discovered evidence and prosecutorial misconduct. The trial court granted him leave and, after an evidentiary hearing, concluded that the State had suppressed material evidence about an alternate suspect and about the uniqueness of Nathan’s pendant. The court also found newly discovered scientific evidence warranted a new trial. The State sought leave to appeal this decision to the First District Court of Appeals, challenging only the Brady violation findings. The appellate court denied leave, reasoning that because the State did not challenge the independent ground of newly discovered scientific evidence, any appeal would be futile.The Supreme Court of Ohio reviewed the case to determine whether the appellate court applied the correct legal standard in ruling on the State’s motion for leave to appeal. The Supreme Court held that the appellate court erred by failing to determine whether the State had shown a high enough probability of trial-court error to warrant a discretionary appeal, as required by App.R. 5(C). The judgment denying leave to appeal was reversed, and the case was remanded for the appellate court to apply the proper standard. View "State v. Jones" on Justia Law

An individual incarcerated at the Belmont Correctional Institution requested various records from the sheriff relating to the operation and administration of the county jail, including policies on inmate intake and booking, personnel employed during a specified period, and records-retention policies. When his attempts to submit the requests by hand delivery and certified mail failed—one being refused and the other returned as undeliverable—he sent the requests by fax. Additionally, a third party, claiming to be his agent, submitted similar requests via email. The sheriff provided some records, stated that others had already been given, and explained that many requested records were maintained by private entities that had operated the jail under contract during relevant periods.The inmate subsequently filed a mandamus action against the sheriff and the jail, but not against the private jail administrators. The Supreme Court of Ohio previously dismissed the claim against the jail as a non-legal entity, and granted a limited writ requiring the sheriff to obtain and provide certain records from the private entities or certify their nonexistence. The court deferred the issue of statutory damages until the sheriff complied. The sheriff requested the records from the private entities, forwarded what was provided to the inmate, and filed a notice of compliance.Reviewing the case, the Supreme Court of Ohio denied the requests for statutory damages and for contempt and sanctions. The court held that the inmate had not shown by clear and convincing evidence that he successfully transmitted his records requests by hand delivery or certified mail, nor that he authorized the third party to submit requests as his agent by email. The court further found no evidence that the sheriff disobeyed or resisted the court’s prior order, noting that the sheriff acted to comply with the writ by seeking records from the private entities and forwarding their responses. The motions for statutory damages, contempt, and sanctions were therefore denied. View "State ex rel. Brown v. Columbiana Cty. Jail" on Justia Law

In this case, two police officers responded to a robbery at a car dealership and pursued the suspects on the highway. During the chase, one officer was shot multiple times by a hidden suspect, and both officers exchanged gunfire with the perpetrator, who was ultimately killed. One officer suffered serious injuries and required extensive medical care. Following the incident, a newspaper reporter requested public records from the Columbus Police Department, including body camera and dash camera footage of the shootout. The police department denied the request for unredacted video footage, citing statutory provisions that protect the privacy of crime victims, specifically Marsy's Law and related Ohio statutes.The Columbus Police Department eventually released redacted versions of the body camera footage, concealing the identities of the two officers and ending the video before the shooting. The newspaper maintained that, as public officials acting in the line of duty, the officers could not be considered "victims" under Marsy's Law and filed an original action in the Supreme Court of Ohio seeking a writ of mandamus to compel production of the unredacted footage.The Supreme Court of Ohio reviewed whether the officers were "victims" under Article I, Section 10a of the Ohio Constitution (Marsy's Law), and thus entitled to privacy protections under the Victim Privacy Law and the Public Records Act. The court held that police officers are "persons against whom crimes can be committed" and therefore qualify as victims under Marsy's Law. As a result, the statutory provisions apply, and the redaction of identifying information from the footage was proper. The court denied the newspaper's request for a writ of mandamus, holding that the newspaper was not entitled to unredacted body camera and dash camera footage identifying the officers. View "State ex rel. GateHouse Media Ohio Holdings II, Inc. v. Columbus Police Dept." on Justia Law

A woman was killed in her Cincinnati apartment on July 31, 2019, after returning home with groceries and a purse. She was attacked in the entryway and strangled with her purse strap. Later that day, her son was stopped by law enforcement in Indiana while driving her car and found in possession of her wallet, which contained her identification, credit cards, and a recent grocery receipt. The son had left his aunt’s home in Georgia days earlier without permission, taking her car, which was later found near the victim’s apartment. Evidence showed the son had traveled from Georgia to Ohio, and surveillance footage placed him near the victim’s home the night before the murder. The victim had been trying to locate her son, believing he was still in Georgia.The Hamilton County Court of Common Pleas convicted the son of two counts of aggravated murder, aggravated robbery, tampering with evidence, and receiving stolen property. The trial court suppressed some of the son’s custodial statements but admitted others, as well as testimony about his prior acts. The First District Court of Appeals found that the trial court erred by admitting certain custodial statements and other-acts evidence, and held these errors were not harmless. It reversed the convictions for aggravated murder, aggravated robbery, and tampering with evidence, finding insufficient evidence for tampering and barring retrial on that count, but allowed retrial on the other charges.The Supreme Court of Ohio reviewed the case and held that, even after removing the erroneously admitted evidence, the remaining evidence overwhelmingly established the son’s guilt for aggravated murder and aggravated robbery beyond a reasonable doubt. The court found the trial court’s errors harmless and reversed the appellate court’s judgment, reinstating the convictions for aggravated murder and aggravated robbery. The court also concluded that the convictions were not against the manifest weight of the evidence. View "State v. Roberts" on Justia Law

Susan Boggs and Fouad Rachid reside in a home owned by Fouad, Inc., located in Olmsted Township near the Cleveland-Hopkins International Airport. Boggs alleges that increased air traffic and airport operations, particularly following a runway expansion project, have caused significant noise, vibrations, and emissions, rendering the property unsuitable for residential use and amounting to a governmental taking. Boggs declined Cleveland’s offer to purchase an avigation easement and subsequently filed a mandamus action against the City of Cleveland, seeking to compel the city to initiate appropriation proceedings to determine compensation for the alleged taking.The case was initially removed to federal court, where Boggs pursued administrative remedies with the Federal Aviation Administration (FAA), but her claims were rejected. After further federal litigation, the district court granted summary judgment to Cleveland on federal claims and remanded the state-law claims to the Cuyahoga County Court of Common Pleas. In state court, both parties moved for summary judgment. The trial court granted summary judgment to Cleveland, finding that Boggs lacked standing because Cleveland, as a municipality, lacked authority to appropriate property outside its boundaries. The Eighth District Court of Appeals affirmed, holding that Boggs’s injury was not redressable since Cleveland could not be compelled to initiate appropriation proceedings for property outside its jurisdiction.The Supreme Court of Ohio reviewed the case and reversed the judgment of the Eighth District Court of Appeals. The court held that under Article I, Section 19 of the Ohio Constitution, a landowner whose property has been taken by a foreign municipality has standing to pursue a mandamus action to force the municipality to institute appropriation proceedings for compensation, regardless of whether the property is located within the municipality’s boundaries. The case was remanded for further proceedings, including consideration of the statute-of-limitations issue. View "State ex rel. Boggs v. Cleveland" on Justia Law

The defendant was indicted in Cuyahoga County, Ohio, on two counts of rape and one count of sexual battery involving a coworker. After a night out, the alleged victim claimed that she awoke in the defendant’s home to find him having intercourse with her. At trial, the defendant moved for judgment of acquittal, arguing that the state had failed to prove the offenses occurred in Cuyahoga County, thus failing to establish venue. The trial court granted the motion based on insufficient evidence of venue and entered a judgment of acquittal.The State of Ohio appealed the trial court’s decision to the Eighth District Court of Appeals both as of right and by seeking leave to appeal. The defendant argued that, under the Supreme Court of Ohio’s prior decision in State v. Hampton, the state could not appeal a judgment of acquittal based on lack of venue. The Eighth District dismissed both appeals in brief entries, relying on Hampton.The Supreme Court of Ohio reviewed the case and overruled its prior decision in State v. Hampton. The court held that venue is not an element of a criminal offense, and a judgment terminating a prosecution based on insufficient evidence of venue is not a judgment of acquittal but rather a dismissal of the indictment, complaint, or information. Therefore, under R.C. 2945.67(A), the state has a right to appeal such a dismissal as of right. The Supreme Court of Ohio reversed the Eighth District’s judgment dismissing the state’s appeal as of right and remanded the case for further consideration. The court affirmed the dismissal of the state’s discretionary appeal as unnecessary. View "State v. Musarra" on Justia Law

A medical-malpractice insurance company based in California issued a policy to a healthcare provider headquartered in Ohio. After a patient sued the provider in Connecticut, the provider submitted the claim to its insurer, which accepted coverage and managed the defense. Disagreements arose between the provider and insurer regarding settlement strategy, leading the provider to self-fund a settlement to avoid the risk of a verdict exceeding policy limits. Subsequently, the provider sued the insurer in Ohio, alleging bad-faith insurance-claim handling and seeking reimbursement for the settlement and related costs.The insurer moved to stay proceedings and compel arbitration under the policy’s arbitration clause, which had been amended to require arbitration of “any dispute…relating to this Policy (including any disputes regarding [the insurer’s] contractual obligations).” The Stark County Court of Common Pleas granted the motion to compel arbitration. On appeal, the Fifth District Court of Appeals reversed, relying on the Ohio Supreme Court’s decision in Scott Fetzer Co. v. American Home Assurance Co., Inc., and held that the bad-faith claim was a tort arising by operation of law and thus not subject to arbitration under the policy’s endorsement.The Supreme Court of Ohio reviewed the case and held that the arbitration agreement in the insurance policy is a broad clause, creating a presumption of arbitrability. The Court found that the presumption was not overcome, as the bad-faith claim could not be maintained without reference to the policy or the insurer-insured relationship, and there was no express exclusion of such claims from arbitration. The Supreme Court of Ohio reversed the Fifth District’s judgment and reinstated the trial court’s order compelling arbitration. View "U.S. Acute Care Solutions, L.L.C. v. Doctors Co. Risk Retention Group Ins. Co." on Justia Law

A prisoner who was serving a sentence for multiple felony offenses believed that the Ohio Department of Rehabilitation and Correction had miscalculated the length of his prison term. Initially, the department determined his sentence to be 11 years, but before his anticipated release, it recalculated the sentence as 13 years. After his original release date passed, the prisoner filed a habeas corpus petition, arguing that his maximum sentence had expired and he was being unlawfully held. The trial court found the sentencing entry ambiguous regarding the sentence length, resolved the ambiguity in the prisoner’s favor, and ordered his immediate release.The warden requested a stay of the trial court’s order, which was denied. The warden then appealed to the Ninth District Court of Appeals and again sought a stay, but the appellate court denied the request due to a procedural deficiency. Without addressing the merits of the appeal, the Ninth District dismissed the case as moot, reasoning that the prisoner’s release and the warden’s failure to secure a stay rendered the appeal moot.The Supreme Court of Ohio reviewed the case to determine whether the prisoner’s release rendered the warden’s appeal moot. The court held that the appeal was not moot because, if the warden prevailed, the prisoner could be returned to custody to serve the remainder of his sentence. The court explained that an actual controversy remained, as effective relief could still be granted. The Supreme Court of Ohio reversed the judgment of the Ninth District Court of Appeals and remanded the case for consideration of the merits of the warden’s appeal. View "Maurent v. Spatny" on Justia Law

A patient alleged that she suffered a neck fracture after falling from her hospital bed while medicated and unattended at a hospital. She filed a complaint against the hospital within the one-year statute of limitations for medical claims, also naming ten John Doe defendants described as unknown medical providers involved in her care. The hospital was served and answered the complaint, but the plaintiff did not obtain summonses or attempt service on the John Doe defendants. Several months later, with the hospital’s consent, she amended her complaint to replace the John Doe defendants with specific individuals and entities, including two doctors and a medical group.The newly named defendants moved to dismiss, arguing that the claims against them were time-barred because they were not named before the statute of limitations expired and the plaintiff had not complied with Ohio Civil Rule 15(D), which governs the naming and service of unknown defendants. The Richland County Court of Common Pleas granted the motion, holding that the statutory 180-day extension for joining additional defendants in medical-claim actions did not apply to defendants who were “obvious” at the outset and that the plaintiff was required to comply with Civil Rule 15(D). The Fifth District Court of Appeals reversed, finding that the statutory extension applied to any additional defendants not named in the original complaint, regardless of whether their existence was contemplated at filing.The Supreme Court of Ohio affirmed the appellate court’s decision. It held that a plaintiff is not required to comply with Civil Rule 15(D) to name additional defendants in an amended complaint under R.C. 2323.451(D)(1), and that the 180-day extension under R.C. 2323.451(D)(2) is not limited to newly discovered defendants. Because the plaintiff properly amended her complaint to join the additional defendants, the extension applied and her action was timely commenced. View "Lewis v. MedCentral Health Sys." on Justia Law

The case concerns a defendant who was convicted by a jury of multiple sexual offenses, including rape, against his young daughter. The central issue on appeal relates to the jury selection process, specifically whether the defendant’s trial counsel was constitutionally ineffective for failing to challenge a particular juror, referred to as Juror McCarthy, for cause. During voir dire, Juror McCarthy expressed some initial uncertainty about his ability to be impartial in a case involving a child witness and indicated discomfort with the presumption of innocence, but also participated in group responses affirming his willingness to be fair and follow the law.After conviction, the defendant appealed to the Twelfth District Court of Appeals, arguing that his counsel’s failure to challenge Juror McCarthy deprived him of a fair trial. The appellate court reviewed the voir dire transcript and concluded that Juror McCarthy’s statements reflected an internal struggle common to many jurors faced with difficult subject matter, rather than actual bias against the defendant. The court also noted that Juror McCarthy, through group responses and direct questioning, indicated he could be fair and impartial. The appellate court therefore rejected the ineffective assistance claim and affirmed the convictions.The Supreme Court of Ohio reviewed the case, focusing on whether a reviewing court may consider group answers during voir dire when determining actual juror bias, and whether a juror who expresses partiality can be rehabilitated through such group responses. The court held that, in assessing actual bias, the entire voir dire record—including group answers—must be considered. The court found that the defendant failed to demonstrate that Juror McCarthy was actually biased, and thus did not establish ineffective assistance of counsel. The Supreme Court of Ohio affirmed the judgment of the Twelfth District Court of Appeals. View "State v. Rogers" on Justia Law