Justia Ohio Supreme Court Opinion Summaries

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

Oak Run Solar Project, L.L.C. sought approval from the Ohio Power Siting Board to construct a solar-powered electric generation facility in Madison County, Ohio. The proposed facility would occupy approximately 4,400 acres and include an 800 MW solar array, a 300 MW battery energy storage system, and two transmission lines. Oak Run entered agreements with landowners for the project site and committed to an agrivoltaics program, maintaining agricultural productivity alongside solar generation. Local governments and other parties intervened, raising concerns about environmental, visual, water, plant, wildlife, and safety impacts. The board’s staff issued a report, and a hearing was held, resulting in project approval subject to conditions for landscape screening and safety.Prior to reaching the Supreme Court of Ohio, the Ohio Power Siting Board considered Oak Run’s application and allowed intervenors, including several township boards and the county board of commissioners, to participate. After a hearing and review, the board granted Oak Run’s certificate for construction, finding the statutory requirements satisfied and imposing conditions related to visual screening and emergency response. The local governments filed an application for rehearing, which was denied. They then appealed to the Supreme Court of Ohio, arguing the board failed to obtain necessary information, especially regarding visual impacts and environmental effects.The Supreme Court of Ohio reviewed the case, applying a standard of review for “unlawful or unreasonable” board orders. The court held that Oak Run failed to provide required photographic simulations or sketches of substations, as mandated by administrative rules, thereby depriving the board of necessary information to assess visual impacts. The court affirmed the board’s orders in part, reversed in part regarding the visual-impact information, and remanded the matter to the board for further consideration of the project’s visual effects. View "In re Application of Oak Run Solar Project, L.L.C." on Justia Law

A 14-year-old boy was accused of raping a 15-year-old boy at a youth home where both resided. The alleged incident took place behind a shed on the property, where a staff member observed the younger boy holding the older boy by the waist and thrusting into him, after overhearing the older boy refuse to engage in further sexual activity. The alleged victim testified that he did not want to participate, felt forced, and had expressed his lack of consent, but did not report any threats or physical harm beyond the act itself.The Hamilton County Juvenile Court magistrate adjudicated the younger boy delinquent for rape, finding that sufficient evidence of force was present, based on testimony that the victim felt compelled and the offender physically held and moved him during the act. The trial judge adopted this finding regarding the incident behind the shed, though dismissed other related charges. The case was then transferred to the Warren County Juvenile Court for disposition, which committed the juvenile to the Department of Youth Services. On appeal, the Twelfth District Court of Appeals affirmed the adjudication, determining that the evidence could support a finding of physical compulsion or constraint sufficient to meet the statutory definition of force.The Supreme Court of Ohio reviewed whether sufficient evidence supported the element of force under R.C. 2907.02(A)(2) for rape in a juvenile delinquency adjudication. Applying the standard used in adult criminal cases, the court held that a rational trier of fact could have found beyond a reasonable doubt that the offender used force, as defined by Ohio law, to compel the victim to submit to sexual conduct. The Supreme Court of Ohio affirmed the judgment of the Twelfth District Court of Appeals. View "In re P.M.S." on Justia Law

After being arrested in connection with several shootings, the defendant was informed of the charges against him at his initial municipal court appearance, where he was appointed counsel and bail was set. Later that day, police detectives interrogated him, reading him his Miranda rights, which he acknowledged and waived by answering questions. During the interrogation, he confessed to involvement in one shooting and a separate theft. About 45 minutes into the interrogation, after being pressed about another crime, he asked, “Like, I can’t talk to a lawyer?” The detective replied that anyone could talk to a lawyer, and the defendant made a statement that was interpreted by the trial court as an invocation of his right to counsel. The interrogation continued, and he made further statements.The Hamilton County Court of Common Pleas granted the defendant’s motion to suppress all statements made during the interrogation. The trial court ruled that Article I, Section 10 of the Ohio Constitution provides a broader right to counsel than the Sixth Amendment, and found that the defendant’s state constitutional right was violated by the interrogation without counsel present. Alternatively, it held that the defendant unambiguously invoked his federal Sixth Amendment right to counsel during the interrogation, requiring suppression of all subsequent statements. The First District Court of Appeals affirmed, relying solely on the Ohio Constitution and interpreting it to provide a broader right to counsel than the federal Constitution.The Supreme Court of Ohio reversed. It held that Article I, Section 10 of the Ohio Constitution guarantees the right to counsel only at “trial,” not at preindictment investigatory interviews, and therefore was not implicated by the interrogation. The court further held that the defendant’s Sixth Amendment right to counsel attached at his initial appearance, but he did not unambiguously and unequivocally invoke that right during the interrogation. The court remanded the case to the trial court, instructing it to vacate its suppression order. View "State v. Morris" on Justia Law

A private company specializing in the disposal of wastewater from oil and gas fracking leased land in an urban area and constructed two saltwater-injection wells. After two earthquakes were recorded near the wells, the State of Ohio determined the company’s activities caused the seismic events and temporarily suspended operations at both wells. One well was later permitted to resume limited operations, but the suspension of the second well remained until 2021. The company had been aware of seismicity risks before acquiring its leasehold and warned investors of possible regulatory shutdowns.After the suspension, the company pursued administrative and judicial challenges, including an appeal to the Ohio Oil and Gas Commission and the Tenth District Court of Appeals, both of which upheld the State’s actions. The company then filed a petition for a writ of mandamus in the Eleventh District Court of Appeals, claiming a regulatory taking of its property. The Eleventh District initially denied relief, but following multiple remands from the Supreme Court of Ohio, it ultimately found no total taking but did find a compensable partial regulatory taking under the Penn Central analysis, ordering the State to initiate eminent-domain proceedings.On appeal, the Supreme Court of Ohio reviewed whether the suspension order constituted a total or partial regulatory taking. The court held that the company failed to prove it was deprived of all economically beneficial use, rejecting the total taking claim. The court further held that, under a proper balancing of the Penn Central factors, the State’s actions did not amount to a compensable partial taking. The Supreme Court of Ohio affirmed the Eleventh District’s denial of the total takings claim, reversed its partial takings finding, and denied the writ of mandamus. View "State ex rel. AWMS Water Solutions, L.L.C. v. Mertz" on Justia Law

A public utility company implemented a power-purchase-agreement rider connected to its contractual share in two coal-fired plants operated by a regional power corporation. This rider could result in either surcharges or credits to retail customers, depending on whether the market revenues from selling the plants’ output exceeded their costs. For the years 2018 and 2019, an independent auditor was hired to review the prudency of all costs and sales associated with this rider and to determine if the company’s actions served the best interests of retail ratepayers. The audit found that while the plants cost customers more than the market price for energy, the company's processes were generally consistent with good utility practice. The audit noted that the “must-run” strategy for plant operation might not always be optimal but considered other factors, such as employment and fuel diversity.The Public Utilities Commission of Ohio previously authorized the rider and allowed cost recovery, subject to annual prudency audits. After the independent audit, the Commission held hearings at which parties, including consumer advocacy groups, challenged the prudency of the must-run strategy and raised concerns about the independence of the audit process. They argued that commission staff improperly influenced the auditor and sought to subpoena a staff member for testimony. The Commission denied the subpoena, finding that testimony from other witnesses covered the relevant issues and that the auditor’s independence was not compromised.On appeal, the Supreme Court of Ohio reviewed the Commission’s findings and procedures. The Court held that the Commission did not commit reversible error in crediting evidence supporting the must-run strategy’s prudency, nor did it violate due process or its own rules by denying the subpoena, since the parties had ample opportunity to cross-examine other key witnesses. The Court also found the Commission was not required to apply an appearance-of-impropriety standard to assess the auditor’s independence. The Commission’s orders were affirmed. View "In re Rev. of the Power-Purchase-Agreement Rider of Ohio Power Co. for 2018 and 2019" on Justia Law

This case concerns a dispute between two women, P.S. and C.E., who were in a romantic relationship for over a decade but never married. During their relationship, P.S. gave birth to three children through artificial insemination. The couple executed a shared-custody agreement for their first child but not for the twins born later. After the relationship ended in early 2015—before same-sex marriage was recognized in Ohio—C.E. sought to be legally recognized as a parent of all three children.In the Hamilton County Court of Common Pleas, a magistrate denied C.E.’s request to be named a legal parent and for shared custody of the twins but awarded her companionship time. The court also declined to terminate the shared-custody agreement for the older child. On objections, the trial court largely upheld the magistrate’s decision but found, through the parties’ words and conduct, that a shared-custody agreement existed for all three children. Both parties appealed.The First District Court of Appeals held that the trial court should determine whether the parties “would have been married” at the time of conception but for Ohio’s ban on same-sex marriage. If so, the court reasoned, C.E. could be recognized as a parent under Ohio’s artificial insemination statute, as required by United States Supreme Court precedent. The court of appeals remanded the case for this determination without addressing other issues raised on appeal.The Supreme Court of Ohio reversed the First District’s judgment, holding that Ohio’s non-spousal artificial insemination statute, by its plain language, applies only to married couples and cannot be retroactively extended to unmarried same-sex partners. The court found no authority in United States Supreme Court precedent to rewrite the statute or to require a “would have been married” inquiry. The cause was remanded to the court of appeals for consideration of the remaining assignments of error. View "In re L.E.S." on Justia Law