Justia Ohio Supreme Court Opinion Summaries

A public utility that provides natural gas service to approximately 450,000 customers in southwestern Ohio had long relied on propane caverns as a seasonal gas supply. After constructing a new pipeline, the utility retired the caverns and sought to recover the costs associated with their retirement—such as the remaining undepreciated value, decommissioning expenses, and the value of the remaining propane inventory—from customers through increased rates. The company had previously obtained approval to abandon the caverns and defer these costs as a regulatory asset, with the understanding that it would seek their recovery in its next base-rate case.The Public Utilities Commission of Ohio reviewed the utility’s application to increase rates. After a hearing, the commission approved an agreement allowing the company to recover the full deferred amount, amortized over ten years as an operating expense. The commission determined that these costs were recoverable under Ohio Revised Code section 4909.15(A)(4) as a cost of rendering public-utility service, and not subject to the “used and useful” standard under section 4909.15(A)(1). The commission also found that, even if the latter standard applied, the costs would still be recoverable.The Supreme Court of Ohio affirmed the commission’s order. The court held that the commission did not act unlawfully or unreasonably in permitting the utility to treat the deferred costs related to the retirement of the propane caverns as operating expenses recoverable under R.C. 4909.15(A)(4). The court further found that these costs were properly considered as current expenses necessary for the provision of utility service, distinguishing them from investment losses in facilities never placed into service. The court dismissed as moot arguments regarding alternative findings and rejected the request to make related rates subject to refund. View "In re Application of Duke Energy Ohio, Inc." on Justia Law

The appellant was convicted in 2008 of several sex offenses and robbery, having committed the crimes prior to May 14, 2007. His original sentencing entry did not include advisements regarding postrelease control or a sex-offender classification. He appealed his conviction, but the absence of these advisements was not raised. Years later, following a new conviction for an offense committed in prison, the trial court, presided over by a new judge, held a hearing in 2018 and issued a journal entry providing postrelease control advisements and classifying him as an aggravated sexually oriented offender under Ohio’s Megan’s Law. The appellant appealed only the imposition of postrelease control, not the sex-offender classification. Ultimately, the Supreme Court of Ohio vacated the postrelease control portion but left the sex-offender classification undisturbed, as it had not been challenged.Subsequently, the appellant filed a complaint for a writ of prohibition in the Eighth District Court of Appeals, arguing that the trial judge had lacked jurisdiction to classify him as a sex offender years after his sentence and final judgment. The Eighth District dismissed his complaint, finding that the judge did not patently and unambiguously lack jurisdiction to conduct the classification and that the appellant could have challenged the classification by direct appeal.On review, the Supreme Court of Ohio affirmed the Eighth District’s dismissal. The court held that because the offenses predated the effective date of Ohio’s Adam Walsh Act, Megan’s Law applied, and the trial judge did not patently and unambiguously lack jurisdiction to classify the appellant under Megan’s Law after sentencing. The court further held that the appellant had an adequate remedy at law through direct appeal to challenge his classification, precluding extraordinary relief in prohibition. View "State ex rel. Bates v. Clancy" on Justia Law

An individual was convicted in 2008 of multiple felonious assault charges and carrying a concealed weapon after a bar fight that resulted in two people being seriously injured. The trial court merged certain counts for sentencing, found the individual to be a repeat violent offender based on stipulations, and imposed an aggregate sentence of 37 years and 6 months, including additional prison terms for repeat violent offender specifications. The individual later argued that his sentence should have expired and that it was unlawfully enhanced based on improper judicial factfinding, and also challenged the sentencing entry’s accuracy and the denial of a motion to correct the record.After conviction, the individual appealed to the Eleventh District Court of Appeals, which affirmed the sentence, finding that the trial court properly imposed the additional terms under mandatory statutory provisions and did not engage in impermissible factfinding. The Ohio Supreme Court declined to review the case. Many years later, the individual filed a motion for a nunc pro tunc order in the trial court, claiming a discrepancy between the sentencing hearing and the written entry, but the motion was denied without a substantive ruling. He did not appeal this denial. Subsequently, he petitioned the Fifth District Court of Appeals for a writ of habeas corpus, raising claims about his sentence, the sentencing entry, and denial of due process; the court granted the warden’s motion to dismiss, ruling that his claims were not cognizable in habeas corpus because he had or could have pursued adequate remedies through direct appeal.The Supreme Court of Ohio reviewed the case and affirmed the judgment of the Fifth District Court of Appeals. The court held that the individual's claims challenging his sentence, the sentencing entry, and the denial of due process were not cognizable in habeas corpus, as any errors would render the sentence voidable, not void, and the individual had adequate remedies in the ordinary course of law. View "State ex rel. Krug v. Stuff" on Justia Law

A 16-year-old was involved in a fatal shooting and was charged in juvenile court with multiple offenses, including aggravated murder and having a weapon while under a disability. After a probable cause hearing, the Juvenile Division of the Cuyahoga County Court of Common Pleas found probable cause for several offenses but not for the weapon under disability charge. As required by law, the court transferred the case to adult court for prosecution of the offenses for which probable cause was found.Once in adult court, a grand jury indicted the defendant on all the original charges from the juvenile complaint plus additional charges, including attempted murder and new counts related to other alleged victims and conduct. The defendant pleaded guilty to murder (an offense for which probable cause had been found), having a weapon while under a disability (for which the juvenile court found no probable cause), and attempted murder (which had not been charged in the juvenile complaint). The trial court sentenced him accordingly.The defendant appealed to the Eighth District Court of Appeals, arguing that the adult court lacked jurisdiction over the attempted murder and weapon under disability charges because the juvenile court had not found probable cause for those. The appellate court, relying on the Supreme Court of Ohio’s prior decisions in State v. Smith and State v. Burns, vacated those convictions.The Supreme Court of Ohio reviewed the matter and overruled its prior decisions in Smith and Burns, holding that when a juvenile court transfers a case to adult court—whether by mandatory or discretionary bindover—it transfers the entire case, including all acts charged in the juvenile complaint. The adult court’s jurisdiction then extends to any offense indicted by the grand jury, not just those for which the juvenile court found probable cause. Accordingly, the Supreme Court of Ohio reversed the Eighth District’s judgment, reinstated the convictions, and remanded for further proceedings on remaining assignments of error. View "State v. Turner" on Justia Law

An inmate submitted four separate public records requests to employees of the Ohio Department of Rehabilitation and Correction and the Bureau of Sentence Computation between October 2024 and March 2025. He sought various documents, including a court journal entry, specific prison kites, and grievances. He alleged that he did not receive the requested records and, in August 2025, filed a mandamus action seeking to compel production of the records and to obtain $4,000 in statutory damages.After the complaint was filed, the respondents answered and evidence was submitted. The record showed that the inmate had received one of the requested records before filing suit, and he received the remaining records after filing. The Supreme Court of Ohio noted that the inmate had also filed a motion for leave to file revised evidence after briefing closed, which the court considered untimely and improper.The Supreme Court of Ohio held that the inmate was not entitled to a writ of mandamus for the record he received before filing his complaint, as there was no actionable claim at that time. For the records provided after the action commenced, the court found the mandamus claim moot because the records had been produced. The court also denied the inmate’s request for statutory damages, applying amendments to the Public Records Act that eliminated statutory damages for inmates in actions filed after April 9, 2025. The court concluded that these amendments were remedial and applied prospectively to all actions filed after their effective date, regardless of when the records were requested. Finally, the court denied the motion for leave to file revised evidence. The writ was denied in part, denied as moot in part, and statutory damages were denied. View "State ex rel. Bates v. Jenkins" on Justia Law

A man was convicted in 2006 of felony domestic violence in Ohio. As a result of this conviction, he was prohibited by both Ohio and federal law from possessing firearms. After completing his sentence and being discharged from post-release control, he sought relief from his Ohio firearms disability under R.C. 2923.14, which allows eligible individuals to petition for restoration of their firearm rights. Seventeen years after his conviction, he applied to the Allen County Court of Common Pleas for relief, arguing that he had led a law-abiding life since his release and was not otherwise prohibited by law from possessing firearms.The Allen County Court of Common Pleas denied his application, reasoning that because federal law independently prohibited him from possessing firearms due to his conviction, he was “otherwise prohibited by law” under R.C. 2923.14(D)(3) and thus not eligible for relief. He appealed this decision to the Third District Court of Appeals. The appellate court reversed the trial court’s judgment, holding that since the same conviction created both the state and federal firearms disabilities, the applicant was not “otherwise prohibited by law,” and remanded the case to the trial court for a discretionary review of the merits of his application.The Supreme Court of Ohio reviewed the appeal by the State. The Court held that a trial court may grant an R.C. 2923.14 application for relief from a state firearms disability when the applicant’s Ohio conviction created both the state and federal firearms disabilities. The Court affirmed the decision of the Third District Court of Appeals and remanded the case to the trial court to determine whether to grant or deny the application based on its discretion. View "State v. Heffley" on Justia Law

Late one evening, emergency personnel responded to a vehicle rollover accident on a four-lane interstate. Police blocked off the two left lanes with several marked vehicles displaying flashing lights to direct traffic into the right lanes, where vehicles moved slowly past the accident. As firefighters assessed the scene and helped a person on the right shoulder, one firefighter began to cross back over the roadway. At that moment, a white sedan accelerated, swerved around multiple parked police vehicles blocking the left lanes, and struck the firefighter at high speed, resulting in his death. The sedan did not stop, but police later located the damaged vehicle and identified the driver, who was subsequently arrested and charged.The case proceeded as a bench trial in the Cuyahoga County Court of Common Pleas, which found the defendant guilty of several offenses, including felony murder (predicated on felonious assault) and failure to comply with an order or signal of a police officer. The court sentenced the defendant to an aggregate term of 16 years to life in prison. On appeal, the Eighth District Court of Appeals reversed the felony murder and failure-to-comply convictions. It concluded that the evidence was insufficient to show the defendant acted “knowingly” as required for felonious assault, modifying the conviction to involuntary manslaughter. The appellate court also determined there was insufficient evidence that any police officer gave the defendant an order or direction, finding that parked police vehicles could not substitute for a direct order.The Supreme Court of Ohio reviewed the case and held that sufficient evidence supported both convictions. It found that driving at high speed through an accident scene, swerving around multiple parked police vehicles with flashing lights, was conduct from which a rational trier of fact could conclude the defendant was aware his actions would probably cause serious physical harm, meeting the “knowingly” standard. The Court also held that police vehicles with flashing lights blocking lanes constituted a lawful order or direction under the failure-to-comply statute. The Supreme Court of Ohio reversed the appellate court’s judgment and remanded the case for further proceedings. View "State v. Bissell" on Justia Law

A local school district board of education filed complaints with a county board of revision, challenging the property tax valuations for two parcels owned by private entities, seeking to increase their assessed values for the 2022 tax year. The county board of revision dismissed the complaints, citing lack of subject-matter jurisdiction under the relevant statute governing complaints against property valuation.After these dismissals, the school board appealed to the Delaware County Court of Common Pleas, relying on a general statute for administrative appeals. The property owners moved to dismiss for lack of jurisdiction, arguing the school board lacked statutory standing. The Court of Common Pleas agreed and dismissed both appeals. The board then appealed to the Fifth District Court of Appeals, contending that the general statute provided an independent right of appeal. The appellate court, however, affirmed the dismissals, concluding that statutory amendments had eliminated the school board’s ability to appeal property valuation decisions to either the Board of Tax Appeals (BTA) or a court of common pleas, unless the board owned or leased the property at issue.The Supreme Court of Ohio reviewed the case. It held that decisions of a county board of revision regarding property valuation are not appealable to a court of common pleas under the general administrative appeal statute (R.C. 2506.01), because those decisions are appealable to a higher administrative authority, the BTA, under R.C. 5717.01. Further, an appeal to the court of common pleas under R.C. 5717.05 is only available to the property owner. Because the school board did not own the properties, it could not appeal under either provision. The Supreme Court of Ohio affirmed the judgment of the Fifth District Court of Appeals. View "Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision" on Justia Law

The case concerns a criminal defendant who pleaded guilty to multiple offenses and was sentenced to a lengthy prison term. The defendant attempted a direct appeal to the Twelfth District Court of Appeals, but his appellate counsel failed to file the required transcript of trial-court proceedings by the court’s deadline. As a result, the direct appeal was dismissed. Several months later, the defendant filed an application under App.R. 26(B) to reopen his appeal, claiming ineffective assistance of appellate counsel for failing to file the transcript. He submitted the trial transcript in support of this application, which the appellate court granted, ultimately affirming his convictions and sentence.Following the unsuccessful reopened appeal, the defendant filed a petition for postconviction relief in the trial court within 365 days of filing the transcript with his App.R. 26(B) application. The State moved to dismiss the petition as untimely, arguing it was not filed within 365 days after the expiration of the time for filing a direct appeal, as required by R.C. 2953.21(A)(2)(a). The trial court dismissed the petition as untimely, and the Twelfth District Court of Appeals affirmed that decision.The Supreme Court of Ohio reviewed whether the deadline for filing a postconviction petition can be triggered by the filing of a transcript with an App.R. 26(B) application to reopen an appeal. The court held that a reopened appeal under App.R. 26(B) does not constitute a direct appeal, and the filing of a transcript in support of such an application does not determine the statutory deadline for seeking postconviction relief. Therefore, the trial court properly dismissed the postconviction petition as untimely. The Supreme Court of Ohio affirmed the judgment of the Twelfth District Court of Appeals. View "State v. Fraley" on Justia Law

The case concerns a public-records request made in March 2020 by the Center for Media and Democracy and its research director, David Armiak, to the Ohio Attorney General’s office. The request sought records related to the office’s involvement with the Republican Attorneys General Association and the Rule of Law Defense Fund. The Attorney General’s office initially produced some documents, submitted others for in camera review, and refused to search for or produce additional records, arguing that the requested documents were not records of the office as defined by Ohio law.After the Attorney General’s office declined further production, Armiak filed a mandamus action in the Tenth District Court of Appeals to compel release of the records. The Attorney General moved to dismiss, asserting that the sought documents were not “records” under Ohio’s Public Records Act and that some categories did not exist. The court’s magistrate denied dismissal, set a briefing schedule, and allowed discovery. Armiak conducted depositions of staff and sought further discovery, including compelling responses to interrogatories and requests for production. The Attorney General objected, citing relevance and proportionality concerns under Civil Rule 26(B)(1), and requested a protective order against his own deposition. The magistrate granted Armiak’s motion to compel and denied the protective order, a decision upheld by the Tenth District Court of Appeals.The Supreme Court of Ohio reviewed the appellate court’s discovery order. It held that discovery in public-records mandamus actions must conform to the purpose and scope of discovery as set forth in Civil Rule 26(A) and 26(B)(1), limiting discovery to information about the nature of the office’s search for records or relevant claims and defenses. The court found the Tenth District misapplied the law and abused its discretion by ordering overly broad discovery and compelling the Attorney General’s deposition. The Supreme Court vacated the discovery order and remanded for proper consideration. View "State ex rel. Ctr. for Media & Democracy v. Yost" on Justia Law