Justia Ohio Supreme Court Opinion Summaries

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

Plaintiff filed this action alleging that Defendant breached certain leases by failing to provide separate meters for utilities inside the leased premises. The trial court granted a preliminary injunction and ordered Defendant to install separate meters for utilities within thirty days. Although Defendant subsequently provided separate meters for the leased premises, the trial court found Dashing Pacific in contempt of court and ordered it to correct certain distribution systems within thirty days or the court would impose a fine of $1,000 per day until Defendant complied with the order. Defendant appealed. The court of appeals denied Plaintiff’s motion to dismiss the appeal, concluding that a contempt citation is final and appealable if it includes both a finding of contempt and pronouncement of a penalty or sanction, even though the order contains purge conditions. The Supreme Court affirmed, holding that a court order finding a party in contempt and imposing a sentence conditioned on the failure to purge is final and appealable on the issue of whether the party is in contempt of court. View "Docks Venture, LLC v. Dashing Pac. Group, Ltd." on Justia Law