Justia Ohio Supreme Court Opinion Summaries

A person sought a civil stalking protection order against another individual in the Franklin County Court of Common Pleas. After the court denied an initial request for ex parte relief, a magistrate conducted a full hearing and granted the protection order. The trial court then adopted the magistrate’s decision and entered a civil stalking protection order against the respondent.Following the entry of judgment, the respondent did not file objections to the magistrate’s decision as permitted and required by the applicable procedural rule, Civ.R. 65.1(G). Instead, he filed a notice of appeal with the Tenth District Court of Appeals. The Tenth District dismissed the appeal, holding that it lacked jurisdiction to review the trial court’s judgment because the respondent had not filed timely objections under Civ.R. 65.1(G). The appellate court subsequently certified that its decision conflicted with those of other Ohio appellate districts on whether the objection requirement was jurisdictional, prompting review by the Supreme Court of Ohio.The Supreme Court of Ohio held that a party’s failure to file objections under Civ.R. 65.1(G) does not deprive a court of appeals of jurisdiction over an appeal from a final civil-protection-order judgment. However, such failure means that the party forfeits appellate review of alleged errors that could have been raised by objection. Furthermore, Civ.R. 65.1 does not provide for plain-error review as a substitute for failing to file objections. As a result, the Supreme Court affirmed, with modification, the appellate court’s disposition, clarifying that jurisdiction existed but the respondent had not preserved his right to challenge the trial court’s alleged errors on appeal. View "A.A. v. S.P." on Justia Law

This case involves a dispute between a county juvenile court and a labor union regarding the interpretation and application of two collective-bargaining agreements covering employees at a juvenile detention center and other court employees. Both agreements contained duration clauses, evergreen clauses, and arbitration provisions. When negotiations for successor agreements failed, the juvenile court declared the agreements expired and ceased recognizing the union. In response, the union filed a grievance and counterclaims, asserting that the evergreen clauses extended the agreements until certain conditions were met and that the court breached the agreements by unilaterally terminating them.Initially, the Cuyahoga County Court of Common Pleas found the agreements were not void ab initio for lack of consideration and recognized an extension of the agreements under the evergreen clauses, but not beyond December 31, 2020, due to public policy. The court ruled the union was entitled to damages for the breach but held that the union’s emailed grievance was not arbitrable, as considering it a grievance would violate public policy. The parties then cross-appealed.The Eighth District Court of Appeals reversed the trial court, holding that disputes concerning the interpretation of the evergreen and duration clauses, as well as the question of when the agreements expired, were subject to arbitration under the agreements. The appellate court ordered the parties to proceed to arbitration.The Supreme Court of Ohio affirmed the Eighth District’s decision. The court held that disputes about the expiration and interpretation of the collective-bargaining agreements are arbitrable, as they concern contract interpretation within the scope of the arbitration clauses. The court found sufficient consideration for the arbitration provisions and determined that challenges to the agreements’ formation did not affect the enforceability of the arbitration clauses. The matter was remanded to the trial court to order arbitration. View "O'Malley v. Laborers' Internatl. Union of N. Am., Local 860" on Justia Law

Three individuals brought suit against the City of Lorain and related entities, alleging that the city charged unlawful rates and fees for water and wastewater services. They moved to certify a class consisting of all ratepayers charged these fees by the city since May 7, 2012. The class action was brought only against the City of Lorain, not the other named defendants.The Lorain County Court of Common Pleas considered whether the plaintiffs met the seven requirements for class certification under Ohio law. The court found that the proposed class was not identifiable or unambiguously defined and that the plaintiffs had not met the “predominance and superiority” requirement under Civ.R. 23(B)(3). However, it determined that the other five requirements were satisfied. Based on the two unmet requirements, the trial court denied the motion for class certification.On appeal, the Ninth District Court of Appeals found the trial court’s analysis to be confusing and seemingly contradictory, as it could not reconcile findings that the class was not identifiable with findings that other requirements were satisfied. The appellate court held that the trial court had failed to conduct the rigorous analysis required and remanded the case for further consideration of the class certification motion.The Supreme Court of Ohio reviewed the case and held that a trial court properly conducts a rigorous analysis of a class certification motion when it addresses each of the seven requirements, even if one or more are not met. The Supreme Court concluded that the trial court’s approach did not render its analysis insufficient or contradictory. Accordingly, the Supreme Court of Ohio reversed the judgment of the Ninth District Court of Appeals and remanded the case to that court to consider the remaining assignments of error. View "Hilton v. Lorain" on Justia Law

A police officer initiated a traffic stop to take an individual into custody for a psychiatric hold following her doctor’s emergency-medical-admission form, which indicated she posed a substantial risk of harm to herself or others. The individual refused to comply with the officers’ instructions to exit her vehicle and resisted being handcuffed, requiring officers to use force to place her in a cruiser. The encounter lasted 15 to 20 minutes. She was charged with obstructing official business and resisting arrest.The Hamilton County Municipal Court granted the defendant’s motion to dismiss both charges, finding her actions did not meet the statutory definition of obstruction because she was not under arrest and could legally refuse to accompany police. The State appealed, and the First District Court of Appeals reversed. The appellate court held that an affirmative act, not necessarily an illegal one, suffices for obstruction under the statute, and that physically resisting officers provided probable cause for both obstruction and resisting arrest charges.The Supreme Court of Ohio reviewed the case on discretionary appeal and as a certified conflict between appellate districts regarding whether obstructing official business requires an illegal act. The court held that under R.C. 2921.31, the State need only allege an unprivileged, voluntary act, whether legal or illegal, that obstructed police officers from performing their lawful duties. The court clarified that Ohio’s civil-commitment statute does not confer a privilege to obstruct official business. The Supreme Court of Ohio affirmed the judgment of the First District Court of Appeals and answered the certified conflict, stating that a charge of obstruction does not require an allegation of an illegal act. View "State v. Dowell" on Justia Law

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