Justia Ohio Supreme Court Opinion Summaries

A circuit court in Boone County, Kentucky entered a multimillion dollar judgment against Stanley Chesley, a former attorney, for his conduct in a class action lawsuit that eventually settled. Chesley filed suit in Ohio state court seeking an injunction to prevent Respondents from collecting on the judgment and to relitigate the case. The Hamilton County Common Pleas Court Judge Robert Ruehlman acted outside its jurisdiction to repeatedly shield Chesley and his assets from creditors. Relator Angela Ford filed a petition for a writ of prohibition to preclude Judge Ruehlman from continuing to exercise jurisdiction over the Hamilton County case. The Supreme Court granted a peremptory writ of prohibition and ordered the judge to vacate his orders, holding that Judge Ruehlman had no statutory authority to grant relief in this case. View "State ex rel. Ford v. Ruehlman" on Justia Law

Appellant filed two complaints for writs of prohibition and a complaint for a writ of procedendo. Appellant sought the writs to restrain a judge and juvenile court from proceeding in litigation regarding contempt charges in an action pending in the juvenile court, to compel two judges and the juvenile court to rule on various motions in the juvenile proceeding, and to prohibit a judge from exercising jurisdiction in a vexatious-litigator action. The court of appeals dismissed the complaints on the basis that Henderson continued to litigate the cases after he had been declared a vexatious litigator. The Supreme Court affirmed the judgments in all three cases because Appellant had been declared a vexatious litigator and failed to fulfill the statutory requirements before continuing litigation in his original actions. View "State ex rel. Henderson v. Sweeney" on Justia Law

Relators, the Ohio Manufacturers’ Association and others, filed this original petition challenging the petition signatures submitted in support of the Ohio Drug Price Relief Act (Act). The committee responsible for the Act petition (committee) filed a motion for judgment on the pleadings, asserting that a challenge to the specific part-petitions at issue did not fall within the scope of the Court’s original jurisdiction. The Supreme Court rejected the committee’s jurisdictional arguments and denied the committee’s alternative arguments for partial judgment on the pleadings, holding (1) the Court has original jurisdiction over this petition challenge pursuant to Ohio Const. art. II, 1g; and (2) the committee’s alternative arguments were unavailing. View "Ohio Manufacturers' Ass’n v. Ohioans for Drug Price Relief Act" on Justia Law

Plaintiff filed an ex parte action for replevin in the county court of common pleas. Plaintiff subsequently voluntarily dismissed the case and filed a complaint for a writ of prohibition in the court of appeals to prevent the court of common pleas judge and magistrate from taking any further action in the dismissed replevin case. The court of appeals issued a short journal entry stating that “this procedendo action is moot” and dismissed the action. The Supreme Court reversed, holding that the court of appeals erred in dismissing the case as a moot action in procedendo. Remanded with instructions that the court of appeals consider the arguments of the parties and conduct an analysis to determine whether a writ of prohibition should be issued. View "State ex rel. Dunn v. Franklin County Court of Common Pleas" on Justia Law

Marcus Pryor applied to the Ohio Department of Job and Family Services (ODJFS) for unemployment compensation. The director of ODJFS concluded that Pryor was ineligible for benefits. A hearing officer with the Unemployment Compensation Review Commission affirmed. The Commission denied Pryor’s request to review the hearing officer’s findings. Pryor filed an appeal in the common pleas court naming the director of ODJFS as the appellee but failing to name the Army, Pryor’s former employer, as a party to his appeal. The common pleas court dismissed the appeal, finding that because Pryor failed to name the Army was an interested party, his notice of appeal did not comply with Ohio Rev. Code 4141.282(D), thus depriving the court of subject-matter jurisdiction. The court of appeals reversed the common pleas court’s dismissal of Pryor’s appeal and reinstated Pryor’s administrative appeal in the common pleas court, ruling that Pryor’s failure to name the Army was not a jurisdictional defect. The Supreme Court reversed, holding (1) the naming of interested parties is not a jurisdictional requirement under section 4141.282; but (2) the Commission failed to comply with the procedural requirements in section 4141.282(D), and therefore, Pryor’s time to appeal the Commission’s decision never started to run. Remanded. View "Pryor v. Dir., Ohio Dep’t of Job & Family Servs." on Justia Law

Sarunas Abraitis, the former executor of his mother’s estate, applied to admit his mother’s will to probate. The will provided that if Abraitis’s father predeceased his mother, her entire estate would be divided equally between Abraitis and his brother, Vytautas. The matter was assigned to Judge Laura Gallagher. While the estate was being administered, Vytautas died. Abraitis subsequently filed an application to probate a different, later will that his mother executed and that bequeathed to him the entire estate. Vytautas’s former wife, Vivian, filed a complaint to contest the later will. The action was also assigned to Judge Gallagher. Abraitis filed two actions in prohibition alleging that Judge Gallagher lacked jurisdiction. As grounds for the writ, Abraitis referred to collateral proceedings regarding his mother’s guardianship and federal and state tax proceedings, arguing that because none of the parties objected or moved to intervene in the tax cases, the probate court was precluded from hearing any matter concerning the estate. The court of appeals dismissed Abraitis’s complaints in prohibition. The Supreme Court affirmed, holding that Abraitis had an adequate remedy in the ordinary course of the law and that Judge Gallagher did not patently and unambiguously lack jurisdiction over the probate court action. View "State ex rel. Abraitis v. Gallagher" on Justia Law

Chester Township and its trustees (collectively, Relators) sought to prohibit Judge Timothy Grendell (Respondent) from issuing or enforcing rulings against them in the case that created the Chester Township Park District, arguing that the probate court lacked subject matter jurisdiction to issue orders attempting to correct activities by the park-district commissioners and the township trustees that frustrated the purpose of the original probate court order creating the park district. The probate court, in turn, asserted that it had continuing subject matter jurisdiction over the case creating the park district. The Supreme Court denied the writ, holding that the township trustees failed to show that the probate court patently and unambiguously lacked jurisdiction to issue the orders at issue. View "State ex rel. Chester Twp. v. Grendell" on Justia Law

This action raised several challenges to recently enacted legislation and administrative rules related to gambling in the state. Plaintiffs filed an amended complaint against several state entities challenging the constitutionality of video lottery terminals and H.B. 1, the act that authorized them, and legislative actions that related to Ohio’s four casinos, particularly H.B. 277 and H.B. 519. Lastly, Plaintiffs claimed that Ohio Const. art. XV, 6, H.B.1, H.B. 277, and H.B. 519 violate equal protection by granting a monopoly to the gaming operators whom the state approved. The trial court granted the state’s motion to dismiss the action for lack of standing and for failure to state claim, concluding that none of the plaintiffs had standing. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiffs failed to establish that they had organizational standing or standing based on their status as individuals experiencing the negative effects of gambling, parents and a teacher of public-school students, and contributors to the commercial-activity tax; and (2) one plaintiff, however, sufficiently alleged standing to survive Defendants’ motion to dismiss his equal protection claim. Remanded. View "State ex rel. Walgate v. Kasich" on Justia Law

Appellant made a request for public records and information based on events surrounding the arrest for another individual. When the Ohio Department of Public Safety (ODPS) denied portions of the request, Appellant filed this action in mandamus. The court of appeals dismissed the petition for mandamus, concluding that ODPS had properly denied portions of Appellant’s request. The court subsequently denied Appellant’s application for reconsideration and en banc consideration, concluding that the requests were a nullity. The Supreme Court affirmed, holding that an application for reconsideration or for en banc consideration under the appellate rules cannot be made in an original action. View "State ex rel. Ziegler v. Ohio Dep’t of Pub. Safety" on Justia Law

Appellant filed a public-records request under the Ohio Public Records Act for the personnel records of six employees of the West Licking Joint Fire District. Less than three business days later, Appellant filed a complaint for a writ of mandamus in the court of appeals. The district’s counsel completed the review of the requested records the same day, and the district sent the documents to Appellant that afternoon. The district did not become aware of Appellant’s complaint until the next day. The court of appeals concluded that the records were produced in a reasonable amount of time and that Appellant had engaged in frivolous conduct. The Supreme Court affirmed in part but found that the court of appeals abused its discretion when it failed to hold a show-cause hearing before finding that Appellant had engaged in frivolous conduct. On remand, the court of appeals held the required hearing and found that Appellant engaged in frivolous conduct, thus awarding attorney fees. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in finding that the continuation of unnecessary discovery after the requested records were provided was frivolous conduct. View "State ex rel. Davis v. Metzger" on Justia Law