Justia Ohio Supreme Court Opinion Summaries

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

NC Enterprises, L.L.C. maintained and landscaped two parcels of land in Tallmadge, Ohio, adjacent to its own property, for many years. Although Norfolk Southern Railway Company held title to these parcels, NC Enterprises regularly hired contractors to mow, weed, fertilize, trim, and otherwise care for the land from shortly after acquiring its own property in 1997 through 2021. In September 2000, NC Enterprises erected a fence on the parcels, and later, in 2011, installed drainage pipes. NC Enterprises believed it owned the parcels until Norfolk Southern posted for-sale signs in 2021. Norfolk Southern paid property taxes on the parcels throughout the relevant period.After Norfolk Southern refuted NC Enterprises’ claim of adverse possession in 2020, NC Enterprises filed suit in the Summit County Court of Common Pleas, seeking a declaratory judgment of adverse possession, quiet title, and damages for unjust enrichment. The trial court granted summary judgment in favor of NC Enterprises on the adverse possession claim, finding that it had proven, by clear and convincing evidence, exclusive, open, notorious, continuous, and adverse use for at least 21 years. Norfolk Southern appealed, and the Ninth District Court of Appeals affirmed, holding that NC Enterprises’ landscaping and maintenance, combined with other acts, sufficed to establish adverse possession.The Supreme Court of Ohio reversed the judgment of the Ninth District Court of Appeals. The court held that NC Enterprises failed to prove that its use of the parcels was open and notorious for the required 21-year period. Specifically, the court concluded that ordinary lawn maintenance, such as mowing and trimming, is not sufficiently obvious or apparent to put the title owner on notice of adverse possession. As a result, summary judgment in favor of NC Enterprises was improper, and the case was remanded to the trial court for further proceedings. View "NC Ents., L.L.C. v. Norfolk & W. Ry. Co." on Justia Law

An individual convicted of aggravated arson, kidnapping, rape, felonious sexual penetration, and aggravated murder with a capital specification in 1986 has, over the years, consistently challenged his conviction and death sentence. After his conviction was affirmed on direct appeal, he pursued habeas corpus relief in federal court, arguing that his intellectual disability rendered him ineligible for the death penalty. These efforts led to extensive state and federal litigation, including multiple appeals and the application of evolving legal standards regarding intellectual disability in death penalty cases.Following the denial of his petition for postconviction relief by the Trumbull County Court of Common Pleas, and affirmance by the Eleventh District Court of Appeals, the petitioner later sought to reopen his case using a motion under Ohio Civil Rule 60(B). He argued that recent changes in the legal standard for determining intellectual disability justified revisiting the prior denial. The trial court treated this motion as an untimely and successive petition for postconviction relief and denied it, finding statutory requirements unmet. The Eleventh District Court of Appeals reversed, holding that Civil Rule 60(B) was an appropriate mechanism for seeking relief from the earlier judgment.The Supreme Court of Ohio reviewed the case and held that Ohio Revised Code section 2953.21 provides the exclusive mechanism for bringing a collateral challenge to the validity of a conviction or sentence in a criminal case. The court held that the Ohio Rules of Civil Procedure, including Rule 60(B), are inapplicable to postconviction relief proceedings, as these are special statutory proceedings governed by specific statutes. Accordingly, the Supreme Court of Ohio reversed the judgment of the Eleventh District Court of Appeals and remanded the matter for consideration of the petitioner’s remaining assignment of error. View "State v. Hill" on Justia Law

A company engaged in electric submetering entered into contracts with the landlords of several apartment complexes, granting it the exclusive right to supply electricity to tenants. These tenants had previously purchased electricity from a traditional utility provider. The submetering company purchased electricity, installed and maintained the necessary distribution and metering equipment, billed tenants directly, set the resale price, and could disconnect service for nonpayment. It profited from the difference between its purchase and resale rates. The landlords received payments from the submetering company but did not control its operations.The utility provider denied requests to convert the complexes to a system allowing the submetering arrangement and filed a complaint with the Public Utilities Commission of Ohio (PUCO), alleging the submetering company was operating unlawfully as a public utility. The submetering company counterclaimed that the utility provider’s blanket policy of denying conversion requests was discriminatory. PUCO concluded that the submetering company was not a public utility, reasoning that the tenants were not “consumers” under the statute and that the company was merely acting as the landlords’ agent. Based on this, PUCO denied the utility provider’s claims but ordered the utility to file a new tariff imposing conditions on the submetering company’s activities. PUCO also found in favor of the submetering company on one counterclaim.The Supreme Court of Ohio reviewed the case and held that the submetering company is “engaged in the business of supplying electricity to consumers” and thus meets the statutory definition of an “electric light company” and a “public utility” under Ohio law. Accordingly, the court reversed PUCO’s orders, vacated its tariff directive and counterclaim finding, and remanded for further proceedings consistent with its holding. View "In re Complaint of Ohio Power Co v. Nationwide Energy Partners, L.L.C." on Justia Law

The case concerns an individual who sought to have the records of seven misdemeanor convictions sealed under Ohio law. These convictions, spanning from 2012 to 2016, included offenses such as unauthorized use of property, attempted theft, disorderly conduct, resisting arrest, and obstructing official business. The applicant, who was working as a licensed parenting counselor and pursuing further education in social work, argued that sealing her convictions was important for her professional advancement and background checks required for her career.The Hamilton County Municipal Court held a hearing on the applications and, despite the absence of opposition from the State of Ohio or the City of Cincinnati, denied the requests. The trial court found that the applicant had not demonstrated her rehabilitation sufficiently, noting her statement that “it’s just not me anymore” as the sole evidence offered. The court also concluded that the government’s interest in keeping the records public, given the nature and number of the offenses and the applicant’s intended field of social work, outweighed her interest in sealing them.On appeal, the First District Court of Appeals reversed the trial court’s decision regarding five of the convictions, holding that the lower court abused its discretion by considering the number and nature of the offenses and by weighing the governmental interest when the State had not objected. The Supreme Court of Ohio reviewed the case and held that the statute does not prevent a trial court from considering the number and nature of an applicant’s convictions when balancing interests, nor does the State’s failure to object prevent the court from considering the government’s interest. The Supreme Court of Ohio found that the court of appeals improperly substituted its judgment for that of the trial court, reversed its judgment in part, and reinstated the trial court’s denial of sealing for the five contested convictions. View "State v. J.B." on Justia Law

An Adams County elector challenged the voter registration of the county prosecuting attorney, alleging that the prosecutor did not actually reside at his registered address in Adams County but instead lived with his family in Hamilton County. The challenger, a qualified elector from Clermont County, submitted evidence including property records, water usage data, and vehicle registrations to support his claim that the prosecutor’s declared residence was not legitimate. The Adams County Board of Elections denied the challenge on two occasions, each time relying solely on its own records and declining to hold a hearing.After the initial challenge was denied, the challenger sought a writ of mandamus from the Supreme Court of Ohio to cancel the prosecutor’s voter registration. The court denied the writ, finding that the relief had not been properly pleaded and declining to address the alternative request for a hearing. In response, the challenger filed a new challenge with the board and, after a second denial without a hearing, again sought mandamus relief from the Supreme Court of Ohio, this time explicitly requesting an order compelling the board to conduct a hearing on his challenge.The Supreme Court of Ohio held that neither claim preclusion nor issue preclusion barred the action, as the new challenge and denial were distinct from the earlier proceeding and the factual question of residency had never been adjudicated in a quasi-judicial hearing. The court found that the challenger had standing under the statute and that the board abused its discretion by denying the challenge without a hearing when its own records were insufficient to resolve the dispute. The court granted a writ of mandamus ordering the Adams County Board of Elections to hold a hearing within ten days on the challenge. The court also denied the board’s request for sanctions against the challenger. View "State ex rel. Hicks v. Adams Cty. Bd. of Elections" on Justia Law

The case centers on the death of an individual, Adam, from a mixed-drug overdose. The defendant, a neighbor named Seymour, facilitated the purchase of heroin for Adam, who had a history of opioid addiction but had reportedly avoided heroin for years prior to the incident. On the day in question, Seymour drove Adam to buy heroin, which he consumed after returning home. He was found dead about an hour later. An autopsy revealed that his death was caused by the combined effects of heroin, mitragynine (kratom), methylphenidate, and diphenhydramine. Expert testimony indicated that while all four drugs had a synergistic effect, heroin was the most likely to result in overdose death among them.After a bench trial, Seymour was convicted of involuntary manslaughter, corrupting another with drugs, and heroin trafficking. She appealed only her convictions for involuntary manslaughter and corrupting another with drugs. The Tenth District Court of Appeals reversed those convictions, holding that the state had failed to provide sufficient evidence that the heroin Seymour provided was a but-for cause of Adam’s death, as no witness had testified that heroin alone caused the death.The Supreme Court of Ohio reviewed the sufficiency of the evidence under the correct standard, emphasizing the role of circumstantial as well as direct evidence. The court held that the but-for test for causation does not require proof that the defendant’s conduct alone caused the harm, only that the harm would not have occurred absent the defendant’s conduct. The presence of other contributing causes does not negate but-for causation. The Supreme Court of Ohio reversed the appellate court’s decision and reinstated the trial court’s judgment, finding sufficient evidence that the heroin Seymour provided was a but-for cause of Adam’s death. View "State v. Seymour" on Justia Law