Justia Ohio Supreme Court Opinion Summaries

James P. Ellis, an inmate at Marion Correctional Institution, has been incarcerated since his 1995 convictions for aggravated burglary and aggravated murder. He contends that the Ohio Adult Parole Authority unlawfully corrected an error in his sentencing entry and has been using this correction in his parole hearings. Ellis sought a writ of prohibition from the Tenth District Court of Appeals to prevent the parole authority from conducting future parole screenings and to compel it to contact the sentencing court for corrective procedures.The Tenth District Court of Appeals dismissed Ellis's complaint. The court reasoned that Ellis did not sufficiently demonstrate that the parole authority lacked jurisdiction or relied on erroneous information. Additionally, the court noted that compelling the parole authority to contact a court is beyond the scope of relief provided by a writ of prohibition.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's dismissal. The court held that the parole authority has jurisdiction to hold parole proceedings for all parole-eligible inmates, including Ellis. The court found that Ellis's parole eligibility is determined by statute, and the parole authority's actions were authorized by law. Consequently, Ellis failed to prove the elements required for a writ of prohibition. The court also noted that Ellis's request to compel the parole authority to contact the sentencing court was not appropriate for a writ of prohibition, which is typically used to prevent unauthorized actions rather than to compel specific actions. View "State ex rel. Ellis v. Adult Parole Auth." on Justia Law

Kenneth Ray Jr. died from asphyxiation due to an industrial accident involving nitrogen gas. His widow, Sharmel Culver, was awarded death benefits and subsequently applied for an additional award, alleging that Ray’s employer, TimkenSteel Corporation, violated specific safety requirements (VSSR). The Industrial Commission of Ohio denied the application, finding that the specific safety requirements did not apply because nitrogen gas is not considered "toxic" or a "poison."Culver sought a writ of mandamus from the Tenth District Court of Appeals, which determined that the commission abused its discretion. The court issued a limited writ, directing the commission to reconsider the VSSR analysis, concluding that nitrogen gas, in the concentration present in the elevator-control room, was toxic and thus fell under the applicable safety regulations.The Supreme Court of Ohio reviewed the case and reversed the Tenth District’s judgment. The court held that the commission did not abuse its discretion in denying the additional award. The court found that the commission’s decision was supported by some evidence, including expert testimony and industry literature indicating that nitrogen gas is not inherently toxic. The court emphasized that the regulations in effect at the time of Ray’s death defined "air contaminants" as including only "toxic" gases, and the evidence did not support a finding that nitrogen gas met this definition. The court concluded that the commission’s interpretation of the regulations was reasonable and that the Tenth District erred in substituting its own judgment for that of the commission. View "State ex rel. Culver v. Indus. Comm." on Justia Law

Thomas Clark, an inmate at Lebanon Correctional Institution (LCI), sought a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction (DRC) to provide records under Ohio’s Public Records Act, R.C. 149.43. Clark also requested $6,000 in statutory damages for six public-records requests he claimed were either denied or ignored by DRC. The requests were made between October 2020 and March 2024, during his incarceration at North Central Correctional Complex (NCCC) and LCI.Clark alleged that he made multiple requests for records, including theft/loss reports and an inmate handbook from NCCC, and chow-hall menus and mail policies from LCI. He claimed that these requests were either ignored or denied. However, Clark did not provide copies of his 2020 and 2021 requests from NCCC, relying instead on a 2024 kite requesting copies of earlier kites. For the LCI requests, Clark provided evidence of his requests for chow-hall menus and mail policies.The Supreme Court of Ohio reviewed the case. The court found that Clark failed to prove he sent the 2020 and 2021 requests to NCCC. Regarding the LCI requests, the court noted that Clark did not direct his requests to the appropriate public-information officer, Ellen Myers, as required by DRC’s protocol. The court held that it is not a violation of the Public Records Act when an employee not responsible for public-records requests directs the requester to the proper office or person responsible for the records.The court denied Clark’s writ of mandamus, as well as his requests for statutory damages and court costs, concluding that Clark did not show a violation of the Public Records Act by DRC. View "State ex rel. Clark v. Ohio Dept. of Rehab. & Corr." on Justia Law

An inmate at the Lebanon Correctional Institution filed a mandamus action against the Ohio Department of Rehabilitation and Correction (DRC) to compel the production of records in response to his public-records requests. He also sought statutory damages and court costs. The inmate requested a memorandum regarding "Legal Dockets," a ViaPath memorandum, and commissary receipts and price lists.The inmate initially sent his request for the "Legal Dockets" memorandum to the warden’s assistant, who asked for a ten-cent payment. The inmate claimed to have submitted the payment, but the assistant stated she never received it. The inmate later received the requested memorandum after filing the mandamus action. For the ViaPath memorandum, the inmate sent his request to the prison’s mailroom department, which directed him to the warden’s assistant. The inmate did not follow up with the assistant. Similarly, for the commissary receipts and price lists, the inmate sent his request to a commissary supervisor, who also directed him to the warden’s assistant, but the inmate did not follow up.The Supreme Court of Ohio reviewed the case. The court denied the writ as moot regarding the "Legal Dockets" memorandum since the inmate received it after filing the action. The court denied the writ for the other requests because the inmate failed to show a violation of the Public Records Act, as he did not direct his requests to the appropriate person responsible for public records. The court also denied the inmate’s requests for statutory damages and court costs, finding that the evidence was evenly balanced on whether the assistant received the payment for the "Legal Dockets" memorandum, and the inmate had filed an affidavit of indigency, meaning there were no costs to award. View "State ex rel. Clark v. Ohio Dept. of Rehab. & Corr." on Justia Law

The appellants, James Ruble, Linda O’Connor, Cynthia Brill, and Suzanne Holland, were administrators employed by the Switzerland of Ohio Local School District Board of Education. In 2021, the board, following the recommendation of a new superintendent, suspended their contracts to streamline the administration, which was deemed overstaffed. The administrators argued that the local policy under which their contracts were suspended was invalid as it did not meet the requirements of R.C. 3319.171.The Seventh District Court of Appeals denied the administrators' petition for a writ of mandamus, which sought reinstatement to their former positions with back pay and benefits. The court found that the board’s policy was valid and that the reasons for the contract suspensions were legitimate. The administrators then appealed to the Supreme Court of Ohio, focusing solely on the argument that the board’s policy was invalid under R.C. 3319.171.The Supreme Court of Ohio affirmed the lower court’s decision, holding that the administrators failed to demonstrate a clear legal right to reinstatement under R.C. 3319.171. The court noted that the statute does not provide a right to reinstatement if a local policy is found deficient. The court also denied the administrators' motion for oral argument, finding the briefs sufficient to resolve the issues. The judgment of the Seventh District Court of Appeals was thus affirmed, and the administrators' contracts remained suspended under the board’s policy. View "State ex rel. Ruble v. Switzerland of Ohio Local School Dist. Bd. of Edn." on Justia Law

A solar energy company, Harvey Solar I, L.L.C., applied to the Ohio Power Siting Board for a certificate to construct a solar-powered electric-generation facility in Licking County, Ohio. The project faced opposition from a local citizens group, Save Hartford Twp., L.L.C., and 11 nearby residents, who raised concerns about the environmental and economic impacts of the project, including visual impacts, flooding, wildlife disruption, noise, water quality, and glare.The Ohio Power Siting Board reviewed the application and conducted an evidentiary hearing. The board staff investigated the potential impacts and recommended approval with conditions. The board ultimately granted the certificate, subject to 39 conditions, including requirements for visual screening, floodplain coordination, wildlife impact mitigation, noise control, and stormwater management.The residents appealed the board's decision to the Supreme Court of Ohio, arguing that the board failed to properly evaluate the project's adverse impacts and that Harvey Solar did not provide sufficient information as required by the board's rules. They contended that the board's decision was unlawful and unreasonable.The Supreme Court of Ohio reviewed the case and found that the board had acted within its statutory authority and had not violated any applicable laws or regulations. The court determined that the board had sufficient evidence to make the required determinations under R.C. 4906.10(A) and that the conditions imposed on the certificate were reasonable and appropriate. The court affirmed the board's order granting the certificate for the construction, operation, and maintenance of the solar facility. View "In re Application of Harvey Solar I, L.L.C." on Justia Law

Emily Johnston began teaching in the North Olmsted City School District in the 2018-2019 school year. Initially, the school board offered her a salary based on ten years of teaching experience, but before she signed the contract, they recalculated it based on six years of experience. Johnston signed the contract with the lower salary. She did not file a grievance under the collective-bargaining agreement (CBA) and later sought a writ of mandamus for the higher salary and backpay.The Eighth District Court of Appeals dismissed Johnston’s complaint, reasoning that she had an adequate remedy through the CBA’s grievance procedure. Johnston argued that the grievance procedure was inadequate because it did not allow for backpay and that she could not use it until her contract was signed. The court found that she had ample opportunity to file a grievance from her first paycheck and that her failure to do so did not make the remedy inadequate.The Supreme Court of Ohio affirmed the Eighth District’s decision. The court held that Johnston had an adequate remedy in the ordinary course of law through the CBA’s grievance procedure, which she failed to utilize. The court also rejected Johnston’s argument that her claim was purely statutory and not subject to the CBA, noting that the CBA implemented the board’s authority under relevant statutes and addressed salary-schedule placement. Therefore, Johnston’s claim was governed by the CBA, and her failure to file a grievance precluded mandamus relief. View "State ex rel. Johnston v. North Olmsted City School District Board of Education" on Justia Law

Chris Shamro sought a writ of mandamus to compel the Delaware County Board of Elections to place a zoning referendum on the May 6, 2025 primary-election ballot. The referendum concerned a zoning amendment for a property in Brown Township owned by Henmick Brewery, L.L.C. The board of elections decertified the referendum from the ballot, finding that the petition did not contain the correct name of the zoning amendment, had a misleading summary, and was accompanied by a misleading map.The board of elections held a protest hearing and voted to sustain the protest and decertify the referendum. Shamro filed a complaint for a writ of mandamus, arguing that the board of elections abused its discretion. The board of elections and Henmick argued that the petition failed to comply with statutory requirements, including providing an accurate summary of the zoning amendment and modifications approved by the board of trustees.The Supreme Court of Ohio reviewed the case and found that the board of elections did not abuse its discretion or act in clear disregard of applicable legal provisions. The court concluded that the referendum petition’s summary was misleading because it did not include approved modifications to the zoning amendment. Therefore, the court denied the writ and Shamro’s request for attorney fees and expenses. View "State ex rel. Shamro v. Delaware County Board of Elections" on Justia Law

Densil Porteous sought a writ of mandamus to compel the Franklin County Board of Elections to place his name on the May 5, 2025 primary-election ballot for Columbus City Council or to reconsider its decision at a public meeting. Porteous had submitted a nominating petition with approximately 332 signatures, but the board validated only 230, falling short of the required 250 signatures. Porteous requested reconsideration, claiming some signatures were wrongly invalidated and offered unsworn statements from signatories as proof.The board initially rejected Porteous's petition due to insufficient valid signatures. Porteous's subsequent requests for reconsideration were denied, and he was informed that the board's verification process was consistent with standards applied to all candidates. Porteous then sought a public hearing for reconsideration, which the board also denied.The Supreme Court of Ohio reviewed the case and held that Porteous failed to demonstrate that the board abused its discretion or acted in clear disregard of the law. The court noted that the board has broad discretion to verify signatures and is not required to accept unsworn statements as proof of authenticity. The court also found no statutory requirement for the board to hold an evidentiary hearing to contest invalidated signatures. Additionally, the court determined that Porteous did not provide clear and convincing evidence that the board treated him differently from similarly situated individuals. Consequently, the court denied the writ of mandamus. View "State ex rel. Porteous v. Franklin County Board of Elections" on Justia Law

An inmate at the Trumbull Correctional Institution (TCI) submitted 17 public-records requests to various TCI departments and employees in August 2023. The requests included documents such as the current bank statement for TCI’s industrial and entertainment fund, the recreation music-room schedule, TCI’s list of approved vendors, and body-camera footage from a specific corrections officer. The inmate claimed that all his requests were initially denied and sought a writ of mandamus to compel the production of the records, as well as statutory damages and reimbursement for postage and photocopying.The case was reviewed by the Supreme Court of Ohio. The court found that many of the inmate’s requests had been rendered moot because the requested documents were provided to him after he filed his complaint. The court also determined that the inmate did not meet his burden of proof for some requests, as he failed to show that he properly requested the records from the appropriate public office or person responsible for public records. Additionally, the court found that the delay in responding to the inmate’s requests was not unreasonable given the number of requests.The Supreme Court of Ohio denied the inmate’s request for a writ of mandamus, statutory damages, and reimbursement for expenses. The court also denied the inmate’s motion to compel the clerk to accept his untimely response and the respondents’ motion for sanctions. The court concluded that there was no evidence that the inmate acted falsely or fraudulently in bringing the action. View "State ex rel. Berry v. Booth" on Justia Law