Justia Ohio Supreme Court Opinion Summaries

Pilkington North America, Inc. entered into a social contract with Toledo Edison Company under which Toledo provided one of Pilkington’s facilities with discounted electric service. The Public Utilities Commission approved the special contract. Pilkington later filed a complaint alleging that Toledo Edison had unlawfully terminated the special contract. Five other companies that also had special contracts with the utility also filed complaints against Toledo Edison. The Commission consolidated the six complaints and dismissed them. With the exception of Pilkington, each of the industrial customers appealed the Commission’s decision. The Supreme Court reversed the Commission’s order, concluding that Toledo Edison had prematurely terminated the special contracts. Pilkington subsequently filed a Ohio R. Civ. P. 60(B) motion for relief from judgment with the Commission seeking relief from the Commission’s order dismissing its complaint and its order denying the application for rehearing that the other five complainants filed. The Commission denied Pilkington’s motion, concluding that Pilkington may not use Rule 60(B) as a substitute for appeal. The Supreme Court affirmed, holding that because Pilkington did not appeal the Commission’s adverse judgment, that judgment is final, and res judicata precludes the use of Rule 60(B) to obtain relief from that final judgment. View "In re Complaint of Pilkington N. Am., Inc." on Justia Law

Christopher Reeves, a federal inmate, sued in mandamus seeking a writ compelling the production of certain records. In his complaint, Reeves alleged that he made a public-records request of the chief of police of the Cedar Point Police Department. Along with his complaint, Reeves filed an affidavit of indigence. The court of appeals dismissed the case because Reeves’s affidavit of indigence was not notarized or accompanied by the certificate of a prison officer verifying Reeves’s lack of funds. The Supreme Court affirmed on the basis that Reeves failed to file a notarized affidavit in support of his request for a waiver of fees and because his complaint for a writ of mandamus was not verified. View "State ex rel. Reeves v. Chief of Police" on Justia Law

In 1989, Petitioner, a prisoner at Grafton Correction Institution, was convicted of aggravated murder and other crimes. After a hearing in 2005, the parole board denied Petitioner parole. The board later determined that it should not have held the parole hearing because Petitioner had not yet served his minimum sentence at that time. Therefore, the board vacated its 2005 decision and continued Petitioner’s parole eligibility to 2015. In 2014, Petitioner filed this original action against the warden, claiming that the parole board violated his due process rights by vacating its 2005 decision. The warden filed a motion for summary judgment under Ohio R. Civ. P. 56(C). The court of appeals granted the motion for summary judgment. The Supreme Court affirmed, holding that the court of appeals (1) did not err by ruling on Petitioner’s motion for summary judgment under the Rules of Civil Procedure; and (2) properly granted summary judgment to the warden based on res judicata, as a habeas corpus action filed by Petitioner in 2013 was virtually identical to the complaint in this case. View "Brooks v. Kelly" on Justia Law

Appellant filed a complaint against the Ohio Department of Natural Resources. A magistrate with the Ohio Court of Claims recommended judgment in favor of the Department. Appellant filed objections to the factual findings in the magistrate’s report and recommendation, but his objections did not include a transcript or affidavit as required by Ohio R. Civ. P. 53(D)(3)(b)(iii). The Court of Appeals entered judgment in favor of the Department. Appellant filed a notice of appeal and also filed a proposed Ohio R. App. P. 9(C) statement of facts in the court of claims. The court of claims rejected the proposed App.R. 9(C) statement and accepted the magistrate’s factual findings as the statement of the evidence. Appellant failed to file his brief in the appeal. The Court of Appeals dismissed Appellant’s appeal. Appellant then commenced this mandamus action to compel the court of claims to settle and approve his Rule 9(C) statement and transmit it to the Court of Appeals as a supplemental record. The Court of Appeals dismissed the complaint. The Supreme Court affirmed, holding that Appellant waived his appeal as to the magistrate’s findings by failing to follow the procedures set forth in Rule 53(D)(3)(b)(iii). View "State ex rel. Pallone v. Ohio Court of Claims" on Justia Law

Plaintiff sued Defendants, alleging that he suffered from spinal injuries as a result of Defendants’ medical malpractice. During discovery, Plaintiff requested a recorded surveillance video that Defendants had created of him. Defendants refused to turn over the video, claiming that it was attorney work product that they intended to use only as impeachment evidence. The court of common pleas ordered Defendants to produce the tape. The court of appeals affirmed the trial court’s order, concluding that the discovery order was final and appealable. The Supreme Court vacated the judgment of the court of appeals, holding that Defendants failed to establish that the trial court’s discovery order was a final, appealable order, and therefore, neither this Court nor the court of appeals had jurisdiction to consider the merits of the interlocutory order. View "Smith v. Chen" on Justia Law

In these consolidated appeals, the Supreme Court considered a trial court’s authority to “conditionally” dismiss a civil case and thereby retain jurisdiction to thereafter enforce a settlement between the parties. These two cases involved claims that arose as a result of a fire in an apartment complex. During a pretrial settlement conference, the parties orally agreed to settle their claims. The trial court sua sponte filed a dismissal entry. The court subsequently clarified that its dismissal was conditional and that it retained jurisdiction to enforce the settlement between the parties. The court of appeals concluded that the trial court’s dismissal entry divested the trial court of jurisdiction and precluded further proceedings. The Supreme Court affirmed, holding (1) a trial court may, when it dismisses a civil action upon notification that the parties have settled, expressly retain jurisdiction for the specific purpose of enforcing the settlement agreement; and (2) because the trial court’s dismissal entry in this case did not incorporate the terms of the settlement agreement or expressly state that the court was retaining jurisdiction to enforce the settlement agreement, the dismissal entry divested the court of jurisdiction and precluded further proceedings. View "Infinite Sec. Solutions, LLC v. Karam Props. II, Ltd." on Justia Law

At issue in this case was Ohio Rev. Code 2907.05(C)(2)(a), which defines “gross sexual imposition” and subjects an offender to a mandatory term of imprisonment when evidence other than the victim’s testimony is admitted corroborating the violation. Appellant in this case pled guilty to two counts of gross sexual imposition. The State introduced testimony regarding Appellant’s alleged confession to the offenses and argued that the confession constituted corroborating evidence, and thus a mandatory prison sentence was required. The trial court concluded that application of section 2907.05(C)(2)(a) violated Appellant’s constitutional rights. The Supreme Court affirmed, holding (1) section 2907.05(C)(2)(a)’s requirement of a mandatory prison term when corroborating evidence is introduced is unconstitutional because corroboration bears no rational relationship to the crime’s activity; and (2) in cases in which a defendant has pled guilty, imposing a mandatory prison term pursuant to section 2907.05(C)(2)(a) when corroborating evidence of the charge of gross sexual imposition is produced violates a defendant’s right to a jury trial. View "State v. Bevly" on Justia Law

In this appropriation action, Appellant was awarded $366,384 in a judgment dated October 4, 2012. Appellant timely moved for attorney fees. On November 27, 2012, the trial court entered its judgment denying attorney fees. However, because there was no instruction to the clerk of courts to serve the entry, the clerk neither served the entry nor noted service on the appearance docket. Appellant received the trial court’s opinion but asked the court to make the judgment final and appealable. On January 30, 2013, the trial court expressly ordered the clerk of courts to serve the November 27, 2012 judgment entry. The clerk of courts complied with the order on that date. On February 4, 2013, Appellant filed a notice of appeal from the November 27, 2012 judgment. The Court of Appeals dismissed the appeal, concluding that it was untimely because it had not been filed within thirty days of the judgment. The Supreme Court reversed with instructions to reinstate the appeal, holding that there is no exception to the requirement that when a trial court issues a judgment, the trial court shall issue a directive to the clerk of courts to serve all interested parties and attorneys with that judgment. View "Clermont County Transp. Improvement Dist. v. Gator Milford, LLC" on Justia Law

After a trial, Defendant was convicted of three counts of complicity to commit aggravated murder, two counts of attempted aggravated murder, and related crimes. After a mitigation hearing, the jury recommended death for the three aggravated murders. The trial court sentenced Defendant to death. The Supreme Court affirmed. Defendant filed a petition for postconviction relief, arguing that his trial counsel provided ineffective assistance by failing to conduct an adequate mitigation investigation prior to his mitigation hearing. The trial court denied Defendant’s petition for postconviction relief. The court of appeals vacated Defendant’s death sentence and ordered a new sentencing hearing, concluding that trial counsel’s decision to present only positive mitigation evidence was unreasonable, and undiscovered mitigating evidence might have influenced the jury’s appraisal of Defendant’s culpability. The Supreme Court affirmed, holding (1) trial counsel were deficient by failing to conduct a thorough and adequate investigation into Defendant’s background before his mitigation hearing; and (2) the court of appeals did not err in determining that counsel’s deficiency was prejudicial under Strickland. View "State v. Herring" on Justia Law

Relators, an employee of Precision Directional Boring, LLC and his wife, commenced an action in the Cuyahoga County Common Pleas Court against Precision and Gary Cole, a coworker at Precision. Cole, a resident of Cuyahoga County, was the only party with a connection to that forum. The Cuyahoga County court granted Precision’s motion to transfer for improper venue and transferred the case to the Medina County Common Pleas Court. The case was subsequently transferred back to Cuyahoga County and then again to Medina County. Relators then filed a complaint in the court of appeals seeking writs of mandamus and procedendo to compel the Cuyahoga County court judge to vacate that court’s transfer orders and adjudicate the underlying action on the merits. The appellate court granted Relators’ motion, concluding that venue was proper in Cuyahoga County. The Supreme Court reversed, holding that Cole’s status as a nominal party prevented Relators from establishing a clear legal right to the vacation of the transfer orders in Cuyahoga county or a clear legal duty by the Cuyahoga County court judge to perform that act, and an appeal would provide an adequate remedy. View "State ex rel. Yeaples v. Gall" on Justia Law