Justia Ohio Supreme Court Opinion Summaries

After a jury trial, Appellant was sentenced to death for the aggravated murder of a police officer. The Supreme Court affirmed Appellant’s convictions and sentence of death, holding (1) the trial court did not err by overruling Appellant’s objection to the State’s peremptory challenge, and the court conducted an adequate voir dire; (2) the trial court did not err by denying Appellant’s motion for a change of venue; (3) the trial court did not commit prejudicial error in its evidentiary rulings or in its instructions to the jury; (4) any questionable conduct that the prosecutor engaged in during the proceedings did not deprive Appellant of a fair trial; (5) Appellant’s counsel provided constitutionally effective assistance; and (6) Appellant’s challenges to the death penalty failed, and the death sentence was appropriate and proportionate in this case. View "State v. Thompson" on Justia Law

The City of Cincinnati charged Daniel Ilg with operating a vehicle while under the influence of alcohol and related offenses. Ilg moved to suppress the results of his breath test taken from an Intoxilyzer 8000 machine. During discovery, Ilg sought computerized online breath archives data consisting of information transmitted by the specific machine used to test him to the Ohio Department of Health (ODH) for each breath test it performed. Ilg sought the data to challenge whether the Intoxilyzer 8000 machine operated properly on the day of his arrest. When the information was not forthcoming, the trial court ordered ODH to disclose the records. The ODH failed to comply with the discovery order, and the trial court ordered as a sanction that the evidence obtained from the Intoxilyzer 8000 be excluded from trial. The Supreme Court affirmed, holding that the sanction was warranted in this case because Ilg was entitled to discovery of relevant evidence to support his claim that the Intoxilyzer 8000 machine used to test him failed to operate properly. View "City of Cincinnati v. Ilg" on Justia Law

Defendant was indicted on two counts of aggravated murder, each of which carried three death specifications. Defendant waived a jury and was tried by a three-judge panel. The panel found Defendant guilty of felony murder and sentenced him to death. The Supreme Court affirmed, holding (1) Defendant’s jury waiver and voluntary, knowing, and intelligent; (2) the procedure whereby the judges were appointed to the panel was not plain error; (3) Defendant’s confession was voluntary; (4) Defendant’s claim that the State violated his Sixth Amendment rights by seizing “attorney work product” during a search of his jail cell was waived at trial; (5) prosecutorial misconduct did not deny Defendant a fair trial; (6) the aggravating circumstances outweighed the mitigating factors in this case beyond a reasonable doubt; and (7) the death sentence in this case was appropriate and proportionate.View "State v. Osie" on Justia Law

After Mother and Father divorced, the parties disputed the custody of their child, A.G. During a court proceeding concerning custody, the juvenile court excluded A.G., who was thirteen years old at the time, from attending the hearing. A.G. had filed a motion to attend the hearing, but the judge denied the motion, concluding that the dispute was between the parents, and therefore, A.G. had not constitutional right to be present. A.G. appealed, claiming that the trial court violated her due process rights by denying her motion to attend the proceeding. The court of appeals affirmed, holding that the trial court had discretion to exclude A.G., a nonparty, from a hearing in custody litigation ancillary to her parents’ divorce. The Supreme Court affirmed, holding (1) in child-custody litigation arising from a divorce, a court has discretion to exclude a child from any proceeding if it determines that exclusion is in the best interest of the child; and (2) the juvenile court in this case considered relevant and appropriate factors in making its decision.View "In re A.G." on Justia Law

Erin McCardle and Leatrice Tolls, protesters involved in the Occupy Cleveland movement in the Public Square area of Cleveland, were arrested and charged with a curfew violation under Cleveland Codified Ordinances 559.541. The ordinance prevents any person from remaining in the Public Square area between 10 p.m. and 5 a.m. without a permit. The defendants moved to dismiss the charges, asserting that the ordinance violated the First and Fourteenth Amendments to the United States Constitution. The Cleveland Municipal Court denied the motions to dismiss. The defendants subsequently pled no contest to the curfew violation. The court of appeals reversed and remanded the cases, holding that the ordinance violated the First Amendment because Cleveland’s interests were insufficient to justify its limit on speech, and the ordinance was not narrowly tailored. The Supreme Court reversed, holding that the ordinance was constitutional under the United States Constitution, as it was content-neutral, narrowly tailored to advance a significant government interest, and allowed alternative channels of speech.View "City of Cleveland v. McCardle" on Justia Law

Defendant was convicted of the aggravated murders of his former mother-in-law, his five-year-old daughter, and his three-year-old son. The trial court sentenced Defendant to death for each of the three aggravated murders. The Supreme Court affirmed, holding (1) the trial court’s denial of Defendant’s motion for a change of venue did not violate Defendant's rights to due process and to a fair trial by an impartial jury; (2) the trial judge did not abuse its discretion in seating two jurors that Defendant claimed were unfairly biased in favor of the death penalty; (3) there was no abuse of discretion in the admission of autopsy photos; (4) the prosecutor did not engage in misconduct; (5) Defendant’s counsel did not provide ineffective assistance; (6) Defendant’s challenges to the death penalty failed; and (7) there was no error in the sentences imposed.View "State v. Mammone" on Justia Law

Defendant pled guilty to the murders of two women and to two counts of abuse of a corpse. After a jury trial, Defendant was convicted of aggravated murder with death specifications for the deaths of two girls. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding, primarily, that (1) the State’s closing remarks in the penalty phase were “improper and substantially prejudicial,” but the Court’s independent evaluation and approval of the capital sentence cured the errors in the penalty-phase proceedings; (2) the trial court did not violate Ohio R. Evid. 404(B) by allowing a witness to testify that when she was thirteen years old Defendant exposed himself to her and offered her five dollars to engage in oral sex; (3) trial counsel did not render ineffective assistance; (4) the State presented sufficient evidence to convict Defendant of attempted rape or robbery in connection the murder of one of the girls; and (5) the sentence was appropriate.View "State v. Kirkland" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated murder and sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in finding that Appellant was competent to stand trial; (2) the trial court did not abuse its discretion in ordering Appellant to wear leg restraints in the courtroom, and even assuming that the order was an abuse of discretion, the error was harmless; (3) the trial court erred in allowing the State to introduce evidence of weapons and ammunition not used in the murders, but the error was harmless; (4) the trial court did not abuse its discretion in introducing the former testimony of Dr. Delaney Smith, a psychiatrist, during the penalty phase, as defense counsel had a prior opportunity to cross-examine Dr. Smith; and (5) the trial court’s sentencing opinion was adequate. View "State v. Neyland" on Justia Law

Defendant was a juvenile when he committed acts constituting aggravated robbery. After a mandatory bindover hearing, the juvenile court relinquished jurisdiction and transferred the matter to the common pleas court. Defendant did not object to the mandatory bindover. Defendant then pleaded guilty to one count of aggravated robbery with a firearm specification. Defendant was sentenced to four years in prison. Defendant appealed, arguing, for the first time, that the statutory mandatory bindover procedures violated his constitutional rights and that defense counsel provided ineffective assistance by failing to raise these claims in the lower courts. The court of appeals affirmed, holding that, by pleading guilty, Defendant had waived his right to challenge either the mandatory bindover or his attorney’s failure to object to it and that Defendant had not demonstrated that his counsel provided ineffective assistance. The Supreme Court affirmed, holding that Defendant forfeited his challenge to the constitutionality of the mandatory bindover statutes by failing to present it to the lower courts. View "State v. Quarterman" on Justia Law

After a jury trial, Defendant was found guilty of felonious assault and carrying a concealed weapon. The appellate court remanded the matter for resentencing, determining that the trial court did not properly impose postrelease control. At the resentencing hearing, Defendant told the trial court that he wanted to represent himself. Thereafter, the court announced that Defendant would be subject to mandatory postrelease control upon release from prison. Defendant appealed, arguing that his right to counsel was violated during the resentencing proceedings and that a resentencing hearing is a critical stage of a criminal proceeding to which the right to counsel attaches. The appellate court affirmed, holding that the trial court had not violated Defendant’s right to counsel by allowing him to represent himself at the resentencing hearing. The Supreme Court affirmed, holding (1) a resentencing hearing is a critical stage of the proceedings to which the right to counsel attaches; and (2) Defendant knowingly, intelligently, and voluntarily waived his right to counsel at the resentencing hearing. View "State v. Schleiger" on Justia Law