Justia Ohio Supreme Court Opinion Summaries

A developer specializing in large-scale data centers agreed to purchase industrially zoned property in Lordstown, Ohio, intending to construct a data center. To proceed, the developer initiated the required site-plan review process under local ordinances in October 2025 by submitting initial materials to the Planning and Zoning Office. Shortly after, the village council passed an ordinance prohibiting data centers, but then repealed it before it took effect. The council instead enacted a temporary moratorium suspending the issuance and processing of permits for new data centers, and later extended this moratorium. As a result, the site-plan review for the developer’s project was halted and did not advance beyond the initial stages.Prior to the present proceedings, the developer and the property seller sought a writ of mandamus in the Supreme Court of Ohio to compel the Village of Lordstown and its planning-and-zoning administrator to continue the site-plan review under the ordinances in effect when the application was first submitted—before the moratorium. The respondents moved to dismiss the petition, and the court dismissed the claim as to the village solicitor but allowed the action to proceed against the other respondents, granting an alternative writ and setting a schedule for merits briefing.The Supreme Court of Ohio concluded that the village lacked a clear legal duty to proceed with the site-plan review while the moratorium was in effect. The court held that the developer did not have a vested legal right to have its site plan reviewed under the prior zoning ordinance because it had not yet met all legislative requirements for a building permit. The court distinguished earlier cases that had found vested rights under different circumstances. Accordingly, the court denied the writ of mandamus, holding that the moratorium lawfully suspended the village’s obligations regarding the site-plan review for data centers during its effective period. View "State v. Lordstown" on Justia Law

A resident submitted a public records request to a local school district in Ohio, seeking an unredacted copy of the district’s check register for a particular month. The school district provided the register but redacted student initials, citing federal and state student privacy laws. The requester contended that such information was not protected and indicated his intent to pursue a legal remedy.Following recent amendments to Ohio’s Public Records Act, a requester must first serve a pre-suit complaint on the public office and allow three business days for the office to cure any alleged failure before initiating a mandamus action. In this case, the requester mailed the required pre-suit complaint to the school district. The certified mail receipt showed delivery on a Monday. The next day, the school district responded, maintaining its position. However, the requester filed a mandamus petition in the Eleventh District Court of Appeals just two days after delivery of the pre-suit complaint, within the three-business-day cure period established by statute.The Eleventh District Court of Appeals dismissed the mandamus petition, holding that the requester failed to comply with the statutory procedure by filing suit before the expiration of the three-business-day period. The court determined that the statutory waiting period is mandatory and that commencing an action before its expiration requires dismissal.On appeal, the Supreme Court of Ohio affirmed the judgment of the Eleventh District. The Supreme Court held that the statutory prerequisite—waiting three business days after service of the pre-suit complaint before filing a mandamus action—was not met. The court concluded that compliance with this procedure is mandatory and that failure to observe it requires dismissal of the action, regardless of the merits of the underlying records dispute. The court also resolved numerous peripheral motions, denying relief on all pending motions except one, which was denied as moot. View "State ex rel. Ames v. W. Geauga Local School Dist. Bd. of Edn." on Justia Law

An individual filed a mandamus action seeking to compel three public offices—the prosecutor’s office, sheriff’s office, and city police—to provide records related to criminal cases involving his incarcerated nephew. He claimed to have sent identical public-records requests to all three offices, seeking a variety of documents, including trial exhibits, ballistics reports, surveillance materials, statements, personnel records, and audio recordings. He received some records in response but alleged that the majority of his requests were not fulfilled.The prosecutor’s office and police department acknowledged receiving his requests and provided partial responses, denying access to certain records due to exemptions and organizational limitations. Both offices presented evidence that the nephew, who is incarcerated, had previously requested the same records and been denied access under Ohio Revised Code 149.43(B)(8), which requires a judge’s approval for incarcerated persons seeking public records. The sheriff’s office, through an affidavit from its risk manager, stated that it had never received a public-records request from the petitioner prior to the mandamus action.The Supreme Court of Ohio reviewed the case. The court held that the petitioner was acting on behalf of his nephew to obtain records that his nephew was not entitled to without judicial approval, and thus the statutory exception under R.C. 149.43(B)(8) applied. The court also found that the petitioner failed to prove he submitted a request to the sheriff’s office. Accordingly, the court denied the writ of mandamus against all respondents and also denied requests for statutory damages, attorney fees, and court costs. Additionally, the court denied a motion by another individual seeking to join the action, as she was not a party to the case. View "State ex rel. Hambel v. Franklin Cty. Prosecutor's Office" on Justia Law

A party entered into a contract for investment-management services with a trust company and later brought suit asserting multiple claims related to the agreement. The plaintiff initially filed the action in the Cuyahoga County Court of Common Pleas in 2016, but voluntarily dismissed it in 2017. Within a year, the plaintiff refiled the action, which was again dismissed without prejudice in 2022. Shortly after, and within one year of the second dismissal, the plaintiff commenced a third action asserting similar claims.The defendants moved for judgment on the pleadings in the trial court, contending that the plaintiff could not invoke Ohio’s saving statute, R.C. 2305.19(A), more than once, as the statute of limitations had expired for some claims before the second refiling. The trial court agreed, holding that the saving statute did not apply to the third action and that the claims were time-barred. On appeal, the Eighth District Court of Appeals affirmed the dismissal of the negligence claims but reversed as to the fraud, breach-of-contract, and promissory-estoppel claims, concluding that the latter had not previously relied on the saving statute because their statute-of-limitations periods had not expired at the time of the second filing.The Supreme Court of Ohio reviewed the case and clarified that R.C. 2305.19(A) does not limit the number of times an action may be recommenced if the statute’s requirements are met, regardless of whether the statute of limitations for a claim expired before a prior use of the saving statute. The court held that the saving statute applied to the entire action and that all claims could proceed. The judgment of the Eighth District was affirmed in part and reversed in part, and the case was remanded for further proceedings. View "Kohn v. Glenmede Trust Co., N.A." on Justia Law

In this case, an individual was indicted in 2022 for involuntary manslaughter related to the 2006 death of a victim who had suffered severe brain trauma as an infant in 1985. The accused had previously been tried and convicted of misdemeanor assault regarding the same injuries in 1985, but the victim survived until 2006. Upon the victim’s death, a coroner determined that the cause was late effects of blunt force head trauma. Although the prosecutor’s office was notified of the death in 2006, no new charges were brought until 2022, after the defendant sought to seal his prior conviction, prompting a renewed investigation.Following the 2022 indictment, the defendant moved to dismiss the charges, arguing that the 16-year delay between the victim’s death and the indictment resulted in missing evidence and unavailable witnesses, thereby prejudicing his defense. The Clermont County Court of Common Pleas held hearings on the motion, including testimony from the deputy coroner, and ultimately found that the defendant had not demonstrated actual prejudice from the delay. The trial court also found no evidence of intentional delay by the State for tactical advantage. The defendant then entered a no contest plea to involuntary manslaughter and was convicted and sentenced. The Twelfth District Court of Appeals affirmed, holding that the defendant failed to show actual prejudice, and thus, the court did not need to consider whether the delay was justified.The Supreme Court of Ohio reviewed the case to clarify the standard for preindictment delay claims. The court held that to succeed, a defendant must show both actual prejudice to his defense and that the delay was an intentional device to gain a tactical advantage for the State. The court overruled prior Ohio precedent that had allowed for a more lenient, burden-shifting standard. Applying the new standard, the court found the defendant failed to establish actual prejudice and affirmed the judgment of the court of appeals. View "State v. Wilson" on Justia Law

A man was accused of raping his four-year-old granddaughter. After being interviewed by detectives, he confessed to the offense. Initially, he was charged by complaint in municipal court, and the matter was transferred to the Knox County Common Pleas Court. There, he waived his right to an indictment and pleaded guilty to a bill of information charging him with rape of a child under the age of ten, though the plea agreement and colloquy misstated the mandatory penalty for the offense. Under Ohio law, such a charge must be prosecuted by indictment, and the right to indictment cannot be waived.After the trial court accepted his guilty plea but before sentencing, the prosecution realized the error in the charging instrument and moved to dismiss the bill of information. The court granted the motion. The case was then presented to a grand jury, which returned an indictment for the same offense. The defendant pleaded not guilty and moved to dismiss the indictment, arguing that double jeopardy barred further prosecution. The trial court denied this motion, finding that jeopardy had not attached to the guilty plea to the unlawful bill of information. The defendant was found guilty in a bench trial, sentenced to 15 years to life, and his conviction was affirmed by the Fifth District Court of Appeals, which rejected his double-jeopardy argument.The Supreme Court of Ohio reviewed the case and held that jeopardy does not automatically attach when a trial court unconditionally accepts a guilty plea. Instead, whether the Double Jeopardy Clauses bar further proceedings depends on whether the defendant had a legitimate expectation of finality in the plea proceeding and whether concerns of prosecutorial overreach existed. Because the original charging instrument was not authorized by law, the defendant never acquired a legitimate expectation of finality, and double jeopardy protections did not apply. The court affirmed the judgment of the Fifth District Court of Appeals. View "State v. Thoen" on Justia Law

A candidate who won the Republican Party nomination for state representative in Ohio’s 89th House District withdrew his candidacy after the primary election. Under Ohio law, a district committee composed of the chairpersons and secretaries of the Republican Party county central committees within the district was authorized to select a replacement candidate. The committee met privately, excluding the public and a board of elections member, and chose Caleb Stidham, who was himself a member and chair of the Erie County Republican Party, as the replacement. The committee certified Stidham’s nomination to the Erie County Board of Elections.When the board of elections considered certifying Stidham for the ballot, it split evenly. The two members against certification cited concerns about the closed committee meeting and Stidham’s participation in his own selection. The Secretary of State, as authorized by statute, broke the tie in favor of certifying Stidham. Shortly after, Carl Koebel, an elector in the district, filed a mandamus action in the Supreme Court of Ohio, seeking to prevent Stidham’s certification and requesting removal from the ballot, arguing that the committee violated Ohio’s Open Meetings Act.The Supreme Court of Ohio reviewed Koebel’s complaint, including arguments regarding the verification affidavit and standing. Ultimately, the court denied the writ on the grounds of laches, finding Koebel had unreasonably delayed for 25 days after the Secretary of State’s decision, thereby prejudicing the board and the Secretary due to statutory deadlines for ballot printing and absentee ballot distribution. The court did not reach the merits of Koebel’s Open Meetings Act claim, instead holding that the delay barred relief. The court also granted Koebel’s motion to submit a supplemental affidavit but denied his request for attorney fees. View "State ex rel. Koebel v. Erie Cty. Bd. of Elections" on Justia Law

The case involves a dispute regarding the eligibility of a candidate for the Ohio general election ballot. Judge Nathan Manning was nominated in the Republican Party primary as a candidate for state representative for the 52nd Ohio House District. Subsequently, a vacancy arose in the Ninth District Court of Appeals due to a judge’s retirement, and Governor Mike DeWine appointed Manning to fill the vacancy until a successor could be elected. Manning withdrew his state representative candidacy and was later selected by a Republican Party district committee as the candidate for the unexpired appellate court term. Mark Derrig, an elector, challenged this selection, arguing that Ohio Revised Code (R.C.) 3513.31(I) prohibited Manning’s selection because he had already been nominated for a different office in the primary election.After Derrig raised his objection, the Summit County Board of Elections convened a hearing but reached a tie vote on whether to remove Manning from the ballot. Ohio Secretary of State Frank LaRose broke the tie, allowing Manning’s candidacy to stand. Derrig then filed an original action for a writ of mandamus in the Supreme Court of Ohio, seeking to compel removal of Manning’s name from the ballot.The Supreme Court of Ohio reviewed Derrig’s claim and interpreted R.C. 3513.31(I) in the context of Ohio’s election statutes. The court held that the statute does not prevent a party district committee from selecting a candidate for a remaining unexpired term in a judicial office, even if that candidate was previously nominated for a different office in the primary election. Therefore, Derrig did not establish a clear legal right to Manning’s removal or a clear legal duty for respondents to provide such relief. The court denied the writ of mandamus. View "State ex rel. Derrig v. LaRose" on Justia Law

In this case, the defendant was charged with two counts of rape after an incident in 2010. The victim testified that after taking a sip of her drink at a bar, she lost memory of events until she awoke in a parking lot, injured and with physical signs suggesting sexual assault. DNA evidence linked the defendant to the victim, and the victim asserted she had not consented to sexual activity. The investigation initially stalled for years until DNA analysis in 2020 identified the defendant as a suspect. The defendant denied any encounter with the victim or presence at the bar, but witness testimony placed him in the vicinity and contradicted his statements.On appeal, the Eighth District Court of Appeals vacated the defendant’s conviction for rape under R.C. 2907.02(A)(1)(c), finding that the State had not proven beyond a reasonable doubt that the defendant knew the victim was substantially impaired. The court also determined that defense counsel had been ineffective for not objecting to certain hearsay testimony presented at trial. Based on these conclusions, the appellate court vacated the conviction and remanded the case to the trial court.The Supreme Court of Ohio reviewed the case and found that the Eighth District had applied the wrong legal standard in assessing the sufficiency of the evidence. The Supreme Court held that the State only needed to present adequate evidence, viewed in the light most favorable to the prosecution, that the defendant knew or had reasonable cause to believe the victim was substantially impaired. The Court also found no ineffective assistance of counsel, as the contested testimony did not undermine the trial’s outcome. The Supreme Court of Ohio reversed the appellate court’s judgment and remanded the case for further proceedings on the remaining claims. View "State v. McClain" on Justia Law

A child, A.S., was adjudicated dependent in 2017 after her mother, C.S., tested positive for drugs at the birth of another child. Temporary custody was granted to the child's paternal grandparents, while the mother entered treatment. After successfully completing her case plan, in 2019, the mother was granted shared legal custody of A.S. with the father, and the case was closed. In 2021, due to the father's illness, the mother was made the residential parent for school purposes. In 2023, following the father's death, the grandparents sought legal custody, citing concerns about the mother's drug history, her marriage to a sex offender, and truancy issues. The mother had limited interaction with A.S. at this time, and evidence was presented regarding her husband’s criminal history and A.S.'s discomfort around him.The Summit County Juvenile Court granted legal custody of A.S. to the grandparents without first finding the mother unsuitable. The mother objected, arguing her parental rights required a finding of unsuitability before custody could be transferred to nonparents. The juvenile court overruled her objections, reasoning that the prior dependency adjudication established unsuitability, and that R.C. 2151.42(B) controlled, requiring only a determination of changed circumstances and best interest. The mother appealed.The Ninth District Court of Appeals affirmed, holding that the juvenile court did not need to find the mother unsuitable before awarding custody to nonparents, since the child had previously been adjudicated dependent. This decision conflicted with precedent from the Eighth District Court of Appeals (In re B.K., 2013-Ohio-1190).The Supreme Court of Ohio reviewed the case and held that when a natural parent has regained legal custody after a dependency finding and the dependency case is closed, a juvenile court may not terminate that custody order under R.C. 2151.42(B) without first finding that the parent has become unsuitable. The judgment of the Ninth District was reversed and the case was remanded for further proceedings. View "In re A.S." on Justia Law