Justia Ohio Supreme Court Opinion Summaries

In this case, the relator, Marcell Strbich, sought a writ of mandamus against the Montgomery County Board of Elections and its members. Strbich claimed that the board failed to provide proper training to precinct election officials regarding the use of unacceptable forms of photo identification, including IDs issued to noncitizens. He requested the court to compel the board to provide this training in accordance with Ohio law and a directive issued by the Secretary of State.The case was reviewed by the Supreme Court of Ohio. The evidence showed that before the evening of September 25, the board did not provide the required training to precinct election officials. Similarly, before September 29, the board did not provide the required training to voting-location managers. The board later updated its training materials and began providing the necessary training from the evening of September 25 for precinct election officials and from September 29 for voting-location managers. The board also planned to email the updated training materials to those who had not received the proper training.The Supreme Court of Ohio found that the case was moot for precinct election officials who attended training on or after the evening of September 25 and for voting-location managers who attended training on or after September 29. However, the case was not moot for those who attended training before these dates. The court granted a writ of mandamus in part, ordering the board to provide the required training to the affected individuals. The board could comply by emailing the updated training materials to these individuals. The writ was denied as moot for those who had already received the updated training. View "State ex rel. Strbich v. Montgomery County Board of Elections" on Justia Law

Plain-clothes detectives from the Central Ohio Drug Enforcement Task Force observed Terrance Cunningham, a known suspected drug trafficker, driving a minivan. They relayed this information to Detective Benjamin Martens, who confirmed that Cunningham did not have a valid driver’s license. Detective Martens located the minivan in a convenience store parking lot, where Cunningham was standing next to the vehicle and Katrina Hale, the passenger, was exiting the store. When questioned, Cunningham claimed Hale was the driver. Hale, appearing nervous, was detained by Detective Martens, who subsequently searched her purses and found methamphetamines.The Licking County Common Pleas Court found that Hale was no longer a passenger when detained and granted her motion to suppress the evidence obtained during the stop, including her statements and the contents of her purses. The court reasoned that since Hale was not in the vehicle at the time of the stop, the detention was unjustified. However, the court did not address whether the search of Hale’s purses was justified independently of her detention.The Fifth District Court of Appeals reversed the trial court’s decision, concluding that Hale remained a passenger and could be detained for the duration of the stop. The appellate court found that the evolving circumstances justified extending the stop and that the search of Hale’s purses was valid under the automobile exception to the Fourth Amendment’s warrant requirement.The Supreme Court of Ohio affirmed the appellate court’s decision, holding that Detective Martens had a reasonable, articulable suspicion to detain Hale as part of the investigatory stop. The court found that Hale’s actions and admissions during the stop provided sufficient grounds for her detention. However, the court did not address the constitutionality of the search of Hale’s purses, as Hale did not develop this argument in her appeal. View "State v. Hale" on Justia Law

A police officer stopped a car because the car’s owner had a suspended driver’s license. Upon approaching the vehicle, the officer realized the driver was not the owner but asked the driver for his license anyway. The driver, who also did not have a valid license, was found with an illegal firearm in the vehicle, leading to the arrest of both the driver and a passenger.The trial court denied the defendants' motions to suppress the evidence found in the car, leading to their no-contest pleas. The Eleventh District Court of Appeals reversed the trial court’s decision, ruling that the officer had no reasonable suspicion to continue the stop after realizing the driver was not the car’s owner. The court held that the evidence obtained from the continued detention should be suppressed.The Supreme Court of Ohio reviewed the case and reversed the Eleventh District’s decision. The court held that under United States Supreme Court precedent, specifically Rodriguez v. United States, an officer who has lawfully initiated a traffic stop may make ordinary inquiries necessary to complete the mission of the stop, including confirming that the driver has a valid driver’s license. The court concluded that the officer did not violate the Fourth Amendment by asking the driver for his license after realizing the driver was not the car’s owner. The judgments of the trial court were reinstated. View "State v. Dunlap" on Justia Law

Mark Gasper was indicted on seven counts of rape under Ohio law, specifically for engaging in sexual conduct with a person whose ability to resist or consent was substantially impaired due to a mental or physical condition. The charges stemmed from a long-term sexual relationship between Gasper and K.W., a 32-year-old woman with cerebral palsy and intellectual disabilities. Gasper was employed as an in-home nurse for K.W.'s siblings, and the incidents occurred in the home where he worked. The state focused on K.W.'s mental impairment, not her physical condition, to argue that she could not consent to sexual conduct.The trial court provided the jury with a standard instruction defining "substantial impairment" as a present reduction in the victim's ability to appraise or control their conduct. During deliberations, the jury asked if medication could be considered when evaluating mental condition, to which the court referred them back to the original instructions. The jury found Gasper guilty on one count and not guilty on the other six. Gasper's motion for acquittal or a new trial, arguing that the court's response to the jury's question changed the state's theory midtrial, was denied.The First District Court of Appeals affirmed the conviction, finding no abuse of discretion in the trial court's denial of Gasper's motion. The appellate court held that the trial court's response did not alter the state's theory and that sufficient evidence supported the conviction, including expert testimony on K.W.'s mental impairment and Gasper's awareness of it.The Supreme Court of Ohio reviewed whether the jury instruction on "substantial impairment" applied to permanent mental conditions. The court held that the instruction, based on the precedent set in State v. Zeh, does include permanent mental conditions. The court found no plain error in the trial court's instructions and affirmed the First District's judgment. View "State v. Gasper" on Justia Law

Columbia Gas of Ohio, Inc. applied to the Ohio Power Siting Board for approval to construct a 3.7-mile natural-gas-distribution pipeline in Maumee, Ohio. The application was submitted under an accelerated review process for pipelines less than five miles long. Yorktown Management, L.L.C., which owns property adjacent to the proposed pipeline route, raised concerns about the safety and environmental impact of the pipeline, particularly its proximity to their commercial office building.The Ohio Power Siting Board approved Columbia's application under the accelerated review process, finding that the project met the necessary criteria. Yorktown filed a motion to intervene and later a motion to suspend the review, arguing that the board had not adequately addressed their safety concerns. The board denied Yorktown's motion to suspend and subsequently denied their application for rehearing, leading Yorktown to appeal the decision.The Supreme Court of Ohio reviewed the case and affirmed the board's decision. The court found that Columbia's application did not require a 50-foot-wide permanent easement along the entire pipeline route, as Yorktown claimed. The court also determined that Yorktown had waived its right to challenge the board's rejection of testimony from a different pipeline project. Additionally, the court held that the board did not err in refusing to suspend its review of the accelerated application, as Yorktown failed to demonstrate good cause for suspension. The court concluded that the board did not improperly defer to Columbia and had appropriately conditioned the approval on compliance with relevant safety regulations. View "In re Letter of Notification Application of Columbia Gas of Ohio, Inc. for the Ford Street Pipeline Project" on Justia Law

In November 1991, a ten-year-old child was kidnapped from her home in Harrison, Ohio, and her body was found days later in Bright, Indiana. Jeffrey Wogenstahl was convicted in 1993 of kidnapping and murdering the child and was sentenced to death by the Hamilton County Court of Common Pleas. The First District Court of Appeals upheld his conviction and sentence, and the Ohio Supreme Court affirmed. Wogenstahl's subsequent petitions for postconviction relief and delayed new-trial motions were denied.Wogenstahl filed a delayed application to reopen his direct appeal nearly 30 years after the original judgment, arguing that his appellate counsel was ineffective for not challenging the trial court's jurisdiction and the constitutionality of R.C. 2901.11(D). The First District Court of Appeals denied the application, concluding that Wogenstahl failed to show good cause for the delay and that his claims were barred by res judicata.The Supreme Court of Ohio reviewed the case and affirmed the lower court's decision. The court held that Wogenstahl did not demonstrate good cause for the nearly 30-year delay in filing his application to reopen. The court also noted that even if good cause had been shown, Wogenstahl's claims were barred by res judicata, as the issue of the trial court's jurisdiction had already been litigated and decided in previous proceedings. The court emphasized that principles of res judicata apply to jurisdictional determinations and that Wogenstahl had ample opportunity to raise his constitutional challenge earlier. View "State v. Wogenstahl" on Justia Law

A group of landowners challenged the Ohio Tax Commissioner’s decision to set a woodland-clearing-cost rate of $1,000 per acre for the purpose of calculating the current agricultural use valuation (CAUV) of their properties for tax years 2015 through 2020. The landowners argued that the rate was too low and not based on reliable evidence, causing their woodlands to be overvalued and resulting in higher property taxes.The Board of Tax Appeals (BTA) upheld the Tax Commissioner’s decision, finding that the Commissioner did not abuse her discretion in setting the $1,000 rate. The BTA concluded that the rate was within the Commissioner’s discretion and based on input from the agricultural advisory committee. The BTA also rejected the Tax Commissioner’s argument that some landowners lacked standing to challenge the CAUV entries for certain years.The Supreme Court of Ohio reviewed the case and found that the Tax Commissioner abused her discretion by adopting the $1,000 rate without reliable evidence or a sound reasoning process. The court noted that the decision was arbitrary and not supported by any fixed rules or standards. The court also found that the Tax Commissioner failed to comply with Ohio Administrative Code 5703-25-33, which requires obtaining information from reliable sources and ensuring that CAUV tables are accurate, reliable, and practical.The Supreme Court of Ohio reversed the BTA’s decision and remanded the case to the Tax Commissioner with instructions to adopt a woodland-clearing-cost rate that complies with the administrative code. The court emphasized that the Tax Commissioner must base the rate on reliable evidence and follow the prescribed standards. View "Adams v. Harris" on Justia Law

The appellant, Mario D. Mays, was charged with multiple offenses, including violating a protection order under Ohio Revised Code (R.C.) 2919.27(A) and (B), a fifth-degree felony. The trial evidence showed that Mays had a prior conviction for violating a protection order. The jury found Mays guilty, and the verdict form specified the violation of R.C. 2919.27(A)(1) and (B)(3). Mays did not object to the verdict form, which, due to his prior conviction, elevated the offense to a fifth-degree felony under R.C. 2919.27(B)(3).The Sixth District Court of Appeals affirmed Mays’s conviction and sentence. Mays argued on appeal that the verdict form was insufficient to convict him of a fifth-degree felony because it did not reference the offense level or any aggravating factors, as required by R.C. 2945.75(A)(2). The appellate court, relying on the Ohio Supreme Court’s decision in State v. Pelfrey, concluded that a statutory reference within the verdict form is sufficient to comply with R.C. 2945.75(A)(2). The court noted that the statutory reference provided adequate notice of the offense degree.The Supreme Court of Ohio reviewed the case to determine if a verdict form’s reference to the statutory section mandating a higher-level offense complies with R.C. 2945.75(A)(2). The court held that such a reference does satisfy the statutory requirement. The court concluded that the verdict form’s citation to R.C. 2919.27(B)(3) was sufficient to state the degree of the offense, thus complying with R.C. 2945.75(A)(2). Additionally, the court applied plain-error review, as Mays did not object to the verdict form at trial, and found no plain error affecting Mays’s substantial rights. Consequently, the Supreme Court of Ohio affirmed the judgment of the Sixth District Court of Appeals. View "State v. Mays" on Justia Law

Imposters, Ltd., a performing-arts theater in Cleveland, sought to place a local liquor option on the November 5, 2024, general-election ballot. The theater holds D-1 and D-2 permits allowing the sale of beer and mixed beverages but not wine or spirituous liquor. Imposters submitted a petition to the Cuyahoga County Board of Elections to allow the sale of wine and spirituous liquor at its location. The board rejected the petition, stating it did not comply with statutory requirements because it did not include "mixed beverages" alongside "wine."The Cuyahoga County Board of Elections reviewed the petition and found it invalid. The board's manager of candidate and petition services informed Imposters that the petition should have included "wine and mixed beverages and spirituous liquor" to be valid. Imposters argued that it did not need to include "mixed beverages" because it already had a permit for mixed beverages. The board unanimously voted to reject the petition and not certify the local liquor option for the ballot.The Supreme Court of Ohio reviewed the case and denied the writ of mandamus sought by Imposters. The court held that the board did not abuse its discretion or act in clear disregard of applicable law. The court found that the petition did not strictly comply with the statutory requirements, specifically R.C. 4301.333(B)(3)(a) and R.C. 4301.355(B)(1), which require the inclusion of "wine and mixed beverages" together. The court concluded that the statutory language did not allow for the separation of "wine" from "mixed beverages" in the petition, and thus, the board's decision to reject the petition was justified. View "State ex rel. Imposters, Ltd. v. Cuyahoga Board of Elections" on Justia Law

A proposed constitutional amendment in Ohio seeks to repeal Articles XI and XIX of the Ohio Constitution and add Article XX, changing the standards and procedures for drawing electoral districts. The amendment would create a 15-member redistricting commission responsible for adopting redistricting plans. Citizens Not Politicians, a coalition aiming to end gerrymandering, and other relators challenged the ballot language and title adopted by the Ohio Ballot Board and Secretary of State Frank LaRose, arguing they were misleading.The Ohio Ballot Board approved the ballot language by a three-to-two vote. Relators filed for a writ of mandamus to compel the board to adopt new language and title. The Supreme Court of Ohio reviewed the case, focusing on whether the ballot language and title would mislead, deceive, or defraud voters. The court found that sections five and eight of the ballot language were misleading. Section five inaccurately limited judicial review to a "proportionality standard," and section eight failed to mention the public's right to participate in the redistricting process through public meetings and hearings.The Supreme Court of Ohio granted a limited writ of mandamus, ordering the Ohio Ballot Board and Secretary of State to reconvene and adopt revised ballot language addressing these defects. The court denied the writ in all other respects, finding the remaining sections of the ballot language and the ballot title to be factually accurate and not misleading. The motion for leave to withdraw the answer was granted, and the motion to strike was denied as moot. View "State ex rel. Citizens Not Politicians v. Ohio Ballot Bd." on Justia Law