Justia Ohio Supreme Court Opinion Summaries

Two Ohio statutes were originally enacted as part of the state’s 2020-2021 budget bill. One statute restricted healthcare providers from soliciting crime or motor-vehicle-accident victims for 30 days after such incidents, and the other created a public records exception for victims’ telephone numbers in police reports. Before these statutes took effect, several healthcare providers challenged their constitutionality in Cuyahoga County Common Pleas Court, arguing that the statutes violated Ohio’s constitutional one-subject rule by exceeding the proper scope of a budget bill. While litigation was ongoing, the General Assembly enacted separate bills that amended both statutes: one changed the solicitation restriction, and two others amended the public records exception.The trial court denied the defendants’ motions to dismiss and subsequently granted summary judgment for the plaintiffs, holding that the two statutes were unenforceable because they originated in a budget bill that violated the one-subject rule. The Eighth District Court of Appeals affirmed this decision, concluding that the subsequent amendments were void since they amended provisions not validly enacted in the first place. The appellate court did not rule on other constitutional claims, finding it unnecessary after resolving the one-subject rule issue.The Supreme Court of Ohio reviewed the case and reversed the Eighth District’s judgment. The court held that when the General Assembly amends a statute through a new bill, the amendment repeals the prior version and enacts the statute anew. Therefore, the constitutionality of the original versions does not render the amended statutes void. The operative law is now the amended language, and any alleged constitutional defects in the earlier versions are irrelevant to the validity of the later-enacted statutes. The case was remanded to the Eighth District for further proceedings on other issues. View "Allied Health & Chiropractic, L.L.C. v. State" on Justia Law

The case concerns a defendant who was indicted in five separate cases in Cuyahoga County, Ohio, for a series of offenses including felonious assault, aggravated robbery, theft, and failure to comply with police. The alleged conduct included assaulting individuals with a vehicle and a baseball bat, shooting at a car, stealing property, and leading police on a high-speed chase. The defendant ultimately entered into a plea agreement with the prosecution, reducing the number and severity of charges in exchange for pleading guilty to nine offenses. During the plea colloquy, the trial court reviewed the charges, the plea agreement, and the defendant's rights, but did not explicitly state that a guilty plea was a complete admission of guilt.After sentencing, the defendant sought to withdraw his plea, expressing disagreement with some victims’ characterizations of the events, but did not assert actual innocence. The Cuyahoga County Court of Common Pleas denied the motion and imposed a ten-year sentence. On appeal, the Eighth District Court of Appeals found that, considering the common understanding of “guilty” and the context of the plea colloquy, the defendant understood the effect of his plea. The court held that the trial court’s failure to explicitly state that a guilty plea is a complete admission of guilt did not render the plea invalid, especially where the defendant did not claim actual innocence.The Supreme Court of Ohio affirmed the Eighth District’s decision. The main holding is that, absent an assertion of actual innocence, a trial court does not completely fail to comply with Ohio Criminal Rule 11(C)(2) merely by omitting an explicit statement that a guilty plea constitutes a complete admission of guilt, provided the plea colloquy otherwise demonstrates the defendant’s understanding. The court also reaffirmed that State v. Griggs remains good law within the clarified framework of State v. Dangler. View "State v. Fontanez" on Justia Law

An inmate at Lebanon Correctional Institution submitted five separate requests for public records to the Ohio Department of Rehabilitation and Correction (ODRC). His requests included copies of ViaPath Technologies’ terms of use and its contract with ODRC, body-worn and stationary-surveillance camera footage from a cell search, Aramark’s food-services contract proposal, recent employee rosters for all departments, and the current recreation schedule. Some requests were denied, while others were partially or fully fulfilled by ODRC, including providing access to certain records or allowing inspection rather than providing physical copies.After receiving responses he considered inadequate, the inmate initiated a mandamus action in the Supreme Court of Ohio. He sought a writ ordering ODRC to produce the requested records and to award him statutory damages for each request. ODRC argued it either did not maintain some of the requested records, had already provided the responsive records, or, in the case of video footage, allowed inspection as required by policy. ODRC also contended that it did not have a legal duty to provide records it did not possess or that no longer existed.The Supreme Court of Ohio held that the inmate was not entitled to a writ or statutory damages for records he failed to show were maintained by ODRC, for body-worn-camera footage not shown to exist, for surveillance footage he had already been permitted to inspect, for records already provided, or for an out-of-date recreation schedule when the current one was supplied. However, the court granted a limited writ regarding the Aramark proposal, ordering ODRC either to provide the document or certify its nonexistence, and deferred ruling on statutory damages for that request until compliance. The inmate’s remaining claims and motions were denied. View "State ex rel. Clark v. Dept. of Rehab. & Corr." on Justia Law

In December 2024, two individuals, Drushal and Eager, initiated a civil action in the Pike County Court of Common Pleas seeking to enforce satisfaction of a prior judgment from the Jackson County Court of Common Pleas against Tyler Miller. The plaintiffs aimed to seize the Millers’ interest in a land contract for real property in Pike County, which the Millers had contracted to purchase from Glenn and Sharon Nickell. The complaint attached the Jackson County certificate of judgment, creating a lien on property owned by Tyler Miller in Pike County. After none of the defendants answered or appeared, Drushal moved for default judgment requesting substitution in the land contract and a writ of possession, as well as a declaration voiding the Nickells’ interest.The Pike County Court of Common Pleas granted a default judgment on May 15, 2025, substituting Drushal for the Millers in the land contract, granting possession to Drushal, and nullifying the Nickells’ interest. The judgment was recorded with the county recorder on June 2, 2025. The Nickells timely appealed to the Fourth District Court of Appeals but did not obtain a stay of execution or post a supersedeas bond. They also filed a motion for relief from judgment under Civil Rule 60(B), which remained unresolved. The appellate court dismissed their appeal as moot, reasoning that the recording of the judgment satisfied it, relying on Blodgett v. Blodgett, and denied the motion to remand for consideration of the Rule 60(B) motion.The Supreme Court of Ohio reversed the Fourth District Court of Appeals. It held that the record did not show a voluntary satisfaction of judgment by the Nickells, as the recording of the judgment was executed by Drushal, not the Nickells. The absence of a stay did not render the appeal moot because restitution could still be available if the judgment were reversed. The Supreme Court remanded the case to the Pike County Court of Common Pleas for consideration of the Nickells' motion for relief from judgment. View "Drushal v. Miller" on Justia Law

In June 2017, a man killed his friend and her two adult daughters in their home. After purchasing weapons and related items, he arranged to visit the home when the daughters were away, but they returned during his visit. He assaulted the mother, then restrained all three women using threats and physical restraints. He proceeded to stab the mother, smother one daughter, and strangle the other, causing all of their deaths. The next day, their bodies were discovered after concerned friends and family entered the home. The suspect was located several days later after a police standoff, subsequently confessed, and was arrested.The case was first heard in the Cuyahoga County Court of Common Pleas, where a three-judge panel accepted the defendant’s guilty plea to multiple counts of aggravated murder, aggravated burglary, kidnapping, and gross abuse of a corpse. After a mitigation hearing, the panel sentenced him to death for each victim. On appeal, the Supreme Court of Ohio vacated the convictions and sentences, finding that the defendant had not been properly advised of certain constitutional rights during his plea. The case was remanded for new proceedings. Upon remand, the defendant again pleaded guilty before a new three-judge panel, which found him guilty and again imposed three death sentences after a mitigation hearing.The Supreme Court of Ohio reviewed the case as a matter of right. The defendant raised numerous legal issues, including claims regarding the weighing of aggravating and mitigating factors, the sufficiency of the indictment, the plea and jury waiver processes, the admission of evidence, and the constitutionality of Ohio’s death penalty scheme. The court overruled all claims. It held that the aggravating circumstances outweighed the mitigating factors beyond a reasonable doubt for each murder and that the death sentences were appropriate and proportionate to similar cases. The convictions and death sentences were affirmed. View "State v. Brinkman" on Justia Law

Six wind farms located in Minnesota, North Dakota, South Dakota, and Iowa, all subsidiaries of Avangrid Renewables, sought certification from the Public Utilities Commission of Ohio (PUCO) to be recognized as eligible Ohio renewable-energy-resource-generating facilities. Such certification would allow these out-of-state wind farms to sell renewable energy in Ohio. Carbon Solutions Group, L.L.C. (CSG), representing Ohio-based renewable energy interests, opposed the applications, arguing that the applicants failed to demonstrate their energy was physically deliverable into Ohio as required by state law.PUCO conducted a three-day evidentiary hearing in December 2022, during which staff, the applicants, CSG, and other interested parties presented testimony and evidence. The central issue was whether the energy generated by these noncontiguous out-of-state facilities could be shown to be deliverable into Ohio. The commission relied on its established Koda test, which uses distribution-factor (DFAX) power-flow studies conducted by regional transmission organizations (RTOs) to determine whether a facility’s energy is physically deliverable into Ohio. After review, PUCO found that the applicants’ DFAX studies, performed by PJM Interconnection, met the required deliverability thresholds and approved all six applications.CSG appealed to the Supreme Court of Ohio, arguing that the evidence was insufficient and that procedural errors occurred, including denial of a subpoena and improper reliance on hearsay. The Supreme Court of Ohio found that PUCO’s order was supported by sufficient evidence and complied with statutory requirements for findings and reasoning. The court held that the commission’s use of the Koda test and reliance on the PJM DFAX studies was reasonable and not against the manifest weight of the evidence or contrary to law. The court also found that CSG’s procedural objections were either waived or jurisdictionally barred. The Supreme Court of Ohio affirmed PUCO’s order. View "In re Application of Moraine Wind, L.L.C." on Justia Law

A federally chartered savings bank headquartered in Pennsylvania operated branches in Ohio and several other states. Ohio taxes financial institutions through a regressive-rate structure, where the tax rate decreases as a bank’s Ohio business increases. The bank claimed that Ohio’s tax scheme forced it to pay more taxes than a bank of similar size operating solely within Ohio, arguing this was unconstitutional discrimination against interstate commerce.The bank filed refund claims with the Ohio tax commissioner for multiple years, asserting the tax was unconstitutional. The tax commissioner denied the request, stating that administrative agencies lack authority to rule on the constitutionality of statutes. The bank then appealed to the Ohio Board of Tax Appeals, which also declined to address the constitutional claim and affirmed the denial of a refund.The Supreme Court of Ohio reviewed the case to determine whether Ohio’s financial-institutions tax violated the dormant Commerce Clause of the United States Constitution. The court applied the internal consistency test, which asks whether identical application of a tax scheme by every state would place interstate commerce at a disadvantage or result in double taxation. The court found that Ohio’s tax only applies to the portion of a bank’s equity capital attributable to its Ohio business and would not result in double taxation if every state adopted a similar scheme. The court also determined that the tax does not discriminate against interstate commerce, as it applies evenhandedly to both intrastate and interstate banks based solely on their Ohio business activity. The court rejected the bank’s arguments and requests for statutory modification, concluding that the tax scheme was constitutional and affirming the decision of the Board of Tax Appeals. View "Dollar Bank, FSB v. Harris" on Justia Law

A worker was severely injured while operating a piece of agricultural machinery at his place of employment. The machine’s power take-off (PTO) shaft, which should have been equipped with safety guards, lacked those guards at the time of the accident. The worker alleged that the absence of these safety guards was due to his employer’s deliberate removal, and that this action directly caused his injuries. He sued his employer for an intentional tort under Ohio law, specifically invoking a statutory provision that creates a rebuttable presumption of intent to injure when an employer deliberately removes an equipment safety guard and an injury results.The Madison County Court of Common Pleas denied the employer’s motion for summary judgment, finding a genuine dispute of material fact as to whether the employer had deliberately removed the safety guard. The case proceeded to trial, where the jury heard evidence about the condition of the machinery, the employer’s repair practices, and the employer’s responses to safety concerns. The jury found in favor of the worker, awarding significant compensatory damages for his injuries. On appeal, the Twelfth District Court of Appeals reversed, holding that the evidence did not support a finding of deliberate removal as a matter of law, and that the statutory presumption did not apply unless the employer both removed the guard and made a conscious decision not to replace it.The Supreme Court of Ohio reversed the judgment of the court of appeals. It held that when reviewing the denial of summary judgment after a trial, appellate courts must consider the full trial record, not just the pretrial record. The court further held that the statutory presumption applies when there is evidence of deliberate removal of a safety guard, and that courts may not require proof of a separate, additional decision not to replace the guard. The case was remanded for further proceedings consistent with this holding. View "Camara v. Gill Dairy, L.L.C." on Justia Law

A church with property insurance sustained windstorm damage and submitted a claim to its insurer. When the parties could not agree on the amount of loss, the church invoked the insurance policy’s binding appraisal process. Each party selected an appraiser, and the appraisers agreed on an award, which the insurer paid and the church accepted. Afterward, the church alleged it discovered additional, previously hidden damages, and the insurer refused to pay more than the appraisal award. The church then sued, claiming breach of contract and seeking to set aside the binding appraisal based on the later-discovered damage.The Franklin County Court of Common Pleas granted judgment on the pleadings to the insurer, finding that the appraisal award was binding and there was no evidence of fraud, misfeasance, or mistake to justify reopening the award. The Tenth District Court of Appeals reversed, holding that the church’s complaint pleaded mistake with sufficient particularity to satisfy Ohio’s Civil Rule 9(B), which requires that mistake be pled with particularity.The Supreme Court of Ohio reviewed the case and held that a binding appraisal award may only be set aside for fraud or manifest mistake, defined as an egregious error undermining the intent of the agreement, not a mere error in judgment. The court further concluded that, to plead mistake with particularity under Civil Rule 9(B), the facts alleged must satisfy the elements of mistake. Since the church only alleged that additional, hidden damages were discovered after the appraisal, and did not plead facts constituting a manifest mistake by the appraisers, the complaint did not state a claim for mistake. The Supreme Court of Ohio reversed the Tenth District’s judgment and reinstated the trial court’s dismissal of the complaint. View "One Church v. Bhd. Mut. Ins. Co." on Justia Law

A theft victim sought restitution from the person who broke into her office and stole property. The offender pleaded guilty to attempted breaking and entering and petty theft. At sentencing, the trial court did not award restitution, despite a request from the victim and supporting documentation. The victim initially filed a timely direct appeal, arguing for restitution under Marsy’s Law, which provides victims certain rights, including restitution. However, while her appeal was pending, she voluntarily dismissed it. Several years later, after related proceedings—including a writ of mandamus directing the trial court to determine restitution—the victim attempted to file a delayed appeal challenging the lack of restitution.After the victim’s direct appeal was dismissed, she sought mandamus relief in the Eighth District Court of Appeals, which partially granted her request by directing the trial court to consider restitution. The trial court scheduled a restitution hearing, but the offender appealed, and the Eighth District vacated the order for a hearing, holding the victim had forfeited the right to challenge restitution by dismissing her earlier appeal. The Supreme Court of Ohio declined jurisdiction over the victim’s appeal from that decision. The victim then moved for leave to file a delayed appeal of the original sentencing order, but the Eighth District denied her request, citing Appellate Rule 5(A), which allows delayed appeals only for defendants, not victims.The Supreme Court of Ohio held that victims seeking to appeal a trial court’s denial of restitution are subject to the procedural requirements of Appellate Rule 4(A) and Appellate Rule 5(A). The court concluded that neither the Ohio nor United States Constitutions require courts to allow victims to file delayed appeals, and that Appellate Rule 5(A)’s limitation to criminal defendants is valid. The judgment of the Eighth District was affirmed, and the victim’s motion for leave to file a delayed appeal was denied. View "State v. Barnes" on Justia Law