Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals dismissing Plaintiff's complaint for a writ of mandamus for noncompliance with Ohio Rev. Code 2969.25(A), holding that where the court's sole basis for dismissing the complaint may have been the result of a docketing error, the complaint should not have been dismissed.When Appellant, an inmate, did not get the desired response to his public-records requests he filed a complaint for a writ of mandamus. The court of appeals dismissed the complaint based on Appellant's alleged failure to file an affidavit of prior actions, as required by Ohio Rev. Code 2969.25(A). The Supreme Court reversed and remanded the case for further proceedings, holding that where the time-stamped affidavit supported Appellant's allegation that he complied with the statute and that the clerk's office failed to place the affidavit in the court file, the court of appeals erred in dismissing the complaint. View "State ex rel. Ware v. Pureval" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that it lacks original jurisdiction over declaratory judgment actions and dismissing the City of East Cleveland's petition for declaratory judgment sua sponte, holding that it is well settled that courts of appeals lack original jurisdiction over claims for declaratory judgment.The City of East Cleveland brought criminal charges against Randolph Dailey and Patricia Coleman, both of whom were sergeants in the Cleveland police department. A jury found Coleman not guilty. In an attempt to obtain review of the trial court's evidentiary rulings before Dailey went to trial, East Cleveland filed a petition for declaratory judgment. The court of appeals dismissed the case for lack of jurisdiction. The Supreme Court affirmed, holding that the court of appeals lacked original jurisdiction over the City's claim for declaratory judgment. View "State ex rel. City of East Cleveland v. Dailey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals ruling that Appellant's complaint for a writ of mandamus is barred by the doctrine of res judicata, holding that the court of appeals correctly applied res judicata to Appellant's claim.Appellant went into the office of the Plain Township zoning inspector to complain about a neighbor's trees, and the inspector told Appellant that the trees did not violate the zoning code. Appellant later filed a mandamus action seeking to compel the inspector and the Plain Township Board of Trustees to enforce the zoning provision against his neighbor. The court of appeals dismissed the complaint. Two years later, Appellant attempted to appeal the inspector's initial decision, but the board of zoning appeals dismissed the appeal as untimely. Appellant then filed a second mandamus action in the court of appeals seeking to compel the inspector to issue his initial decision in writing. The court of appeals held that res judicata barred the claim because Appellant could have asserted that claim in his first mandamus action. The Supreme Court affirmed, holding that the court of appeals correctly applied res judicata to Appellant's claim against the inspector in this case. View "State ex rel. Armatas v. Plain Township Board of Zoning Appeals" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for writs of mandamus and procedendo against Ashtabula County Court Judge David A. Schroeder, holding that Appellant had an adequate remedy in the ordinary course of the law.Appellant filed a petition seeking a writ of mandamus ordering Judge Schroeder to grant his motion to vacate a trial court's judgment denying his motion for the return of his fine and court costs and seeking a writ of procedendo compelling Judge Schroeder to provide the clerk of courts with proper certification of the total amount of money to be returned to Appellant. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that because Appellant had an adequate remedy in the ordinary course of the law Appellant's request for extraordinary relief in mandamus and procedendo was barred. View "State ex rel. Davies v. Schroeder" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court awarding Appellee costs to recover the cost of procuring deposition transcripts after an discrimination lawsuit was resolved on summary judgment, holding that Ohio Rev. Code 2303.21 does not provide statutory authority for a party to recover the cost of deposition transcripts used in support of a motion for summary judgment.Appellant sued Appellee for age discrimination. Over the course of litigation the parties took five depositions. Appellee filed a motion for summary judgment citing to the transcripts of the depositions in support of its motion. The trial court granted the motion for summary judgment. Thereafter, Appellee moved to recover the cost of procuring the deposition transcripts pursuant to section 2303.21. The trial court granted the motion. The Supreme Court reversed, holding that the statute does not allow the expense of procuring deposition transcripts to be taxed as a cost. View "Vossman v. AirNet Systems, Inc." on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's motion for relief from a judgment dismissing his mandamus action against the Ohio Adult Parole Authority and the Bureau of Sentence Computation (collectively, the APA), holding that the court of appeals properly denied Appellant's motion for relief from judgment.In his complaint for a writ of mandamus Appellant, an inmate, alleged that he should have been eligible for parole in 2019 but that the APA had his first hearing scheduled for 2024. The court of appeals dismissed the complaint after adopting the recommendation of the magistrate. Appellant then filed a motion for relief from judgment. The court of appeals denied the motion, ruling that Appellant was barred from asserting that the court of appeals committed any error in adopting the magistrate's decision. The Supreme Court affirmed, holding that Appellant's propositions of law were either waived or without merit. View "State ex rel. Franks v. Ohio Adult Parole Authority" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of prohibition and dismissed as moot the motions Appellant filed in connection with the complaint, holding that the court of appeals correctly dismissed the complaint.In his complaint, Appellant sought to vacate charging orders and receivership orders concerning his membership interests in two limited liability companies, asserting that the orders exceeded the authority of Henry County Court of Common Pleas Judge John Collier. The court of appeals dismissed the complaint, concluding that Judge Collier did not patently and unambiguously lack jurisdiction to enter a charging order or to appoint a receiver. The Supreme Court affirmed, holding that because Judge Collier had subject matter jurisdiction to enter a charging order and to appoint a receiver, Appellant did not show that the judge patently and unambiguously lacked jurisdiction. View "State ex rel. Kerr v. Collier" on Justia Law

The Supreme Court dismissed this appeal from the court of appeals' dismissal of Appellant's petition for a writ of prohibition against Summit County Court of Common Pleas and Judge Mary Margaret Rowlands, holding that this cause was moot.National Collegiate Student Loan Trust 2007-2 filed a civil action against Appellant in the court of common pleas. Judge Rowlands demised the case without prejudice and then reinstated the case after considering National Collegiate's motion for relief from judgment. Petitioner filed a petition for a writ of prohibition alleging that Judge Rowland lacked jurisdiction to issue the order reinstating the case. The court of appeals dismissed the petition for failure to state a claim. Appellant appealed. Judge Rowlands claimed that the appeal was moot because, during the pendency of the appeal, she dismissed National Collegiate's case a second time. The Supreme Court dismissed the appeal, holding that the cause was moot and that no exception to the mootness doctrine applied. View "State ex rel. Ames v. Summit County Court of Common Pleas" on Justia Law

The Supreme Court found Larry Greene in contempt for failing to provide records under the terms of an existing peremptory writ of mandamus and imposed a sanction of $1,000, holding that Greene failed to meet his obligations under both Ohio's Public Records Act and the peremptory writ of mandamus issued by this Court.When Jerone McDougald was an inmate at the Southern Ohio Correctional Facility (SOCF) he sent a public records request to Greene, SOCF's public records custodian. When Greene did not provide copies of the requested document McDougald filed an action for a writ of mandamus. The Supreme Court granted a peremptory writ. Later, the McDougald filed a motion asking that Greene be held in contempt for court for withholding the requested document. The Supreme Court held that Greene failed to meet his obligations, found him in contempt of court, and imposed a sanction, which the Court stayed to allow Greene the opportunity to purge the contempt in a manner outlined by the Court. View "State ex rel. McDougald v. Greene" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's order confirming the sale of Homeowners' property after the trial court entered a foreclosure decree in favor of Bank, holding that the foreclosure decree was a final, appealable order.Homeowners challenged the trial court's entry of a foreclosure decree in favor Bank. The court of appeals dismissed the appeal for lack of a final, appealable order because the foreclosure decree did not state the amounts owed to two other lienholders. During the appeal, Homeowners' property was sold at a sheriff's sale. Homeowners' second appeal challenged the trial court's order confirming the sale of the property. The court of appeals concluded that the law-of-the-case doctrine required adherence to its earlier decision that the foreclosure decree was not a final, appealable order, and therefore, the trial court had no authority to confirm the sale. The Supreme Court reversed and reinstated the trial court's confirmation of sale, holding that the foreclosure decree against Homeowners was a final, appealable order that fully addressed the rights and responsibilities of all parties. View "Farmers State Bank v. Sponaugle" on Justia Law