Justia Ohio Supreme Court Opinion Summaries

Thomas Brown ran unsuccessfully to become the Democratic nominee for a seat on the Ashtabula County common pleas court in the Democratic Party primary election. Brown subsequently filed nominating petitions to be a judicial candidate on the Ashtabula County Western Area Court in the general election. The Ashtabula County Board of Elections (Board) rejected Brown’s petitions based on the ballot-access restrictions set forth in Ohio Rev. Code 3513.04. Relators, including Brown, subsequently sought a writ of mandamus compelling the Board and its director (collectively, Respondents) to certify Brown’s candidacy for the Western Area Court, asserting that section 3513.04 is unconstitutional. The Supreme Court denied the writ, holding that Relators failed to overcome the presumption of constitutionality and failed to demonstrate that section 3513.04 is unconstitutional beyond a reasonable doubt. View "State ex rel. Brown v. Ashtabula County Bd. of Elections" on Justia Law

After a jury trial, Defendant was found guilty of the aggravated murder of Nichole McCorkle and sentenced to death. The Supreme Court affirmed the judgment of conviction and the sentence of death, holding, among other things, that (1) the trial court did not err in admitting the autopsy report on McCorkle and by allowing a medical examiner, who did not conduct the autopsy, to testify about the autopsy results because an autopsy report that is neither prepared for the primary purpose of accusing a targeted individual nor prepared for the primary purpose of providing evidence in a criminal trial is nontestimonial and its admission into evidence at trial as a business record does not violate a defendant’s Sixth Amendment confrontation rights; (2) trial counsel did not provide constitutionally ineffective assistance; and (3) the trial court did not err by failing to appoint a neurologist to develop mitigation.View "State v. Maxwell" on Justia Law

Defendant was convicted of three counts of aggravated murder and other felony offenses. The Supreme Court affirmed Defendant’s convictions and sentence of death, holding (1) even if the trial court overstepped its bounds in conducting an Adkins hearing, no prejudice occurred; (2) Defendant’s waiver of a jury trial was voluntary, knowing, and intelligent; (3) the prosecutor did not engage in misconduct; (4) Defendant’s counsel provided constitutionally effective assistance; (5) the three-judge panel did not violate Defendant’s constitutional rights by choosing to give certain mitigating evidence no weight and limited weight; and (6) Defendant’s remaining claims similarly failed. View "State v. Jackson" on Justia Law

Appellee filed an employment-discrimination action against the Dayton Police Department (DPD) and Major Mitchell Davis, her supervisor, alleging, inter alia, age- and sex-based discrimination in violation of Ohio Rev. Code 4112 and Title VII of the Civil Rights Act. DPD and Davis filed a motion for summary judgment, arguing that Davis was entitled to immunity on the basis that a supervisor employed by a political subdivision cannot be held individually liable in a discrimination action. The trial court denied the motion for summary judgment as it related to Appellee’s claim of sex discrimination under Chapter 4112 and denied the motion as it related to Davis’s claim of immunity. The court of appeals affirmed on the basis that Ohio Rev. Code 2744.03(A)(6)(c), which states that political-subdivision employees, such as Davis, are not entitled to immunity if civil liability is expressly imposed upon the employee by a section of the Revised Code. The Supreme Court reversed, holding that Ohio Rev. Code 4112.01(A)(2) and 4112.02(A) do not expressly impose civil liability on political-subdivision employees so as to trigger the immunity exception in section 2744.03(A)(6)(c). View "Hauser v. Dayton Police Dep’t" on Justia Law

Plunderbund Media, LLC sought the disclosure of records documenting threats against the governor that were kept by the Director of Public Safety. Legal counsel for the Department of Public Safety refused to produce any records based on Ohio Rev. Code 149.433, which exempts “security records” from disclosure under the Public Records Act. Plunderbund filed an action for a writ of mandamus to require the Department to produce the requested records. The Supreme Court denied the writ, holding any records of threats made to the governor are “security records” and are therefore exempt from disclosure as public records under section 149.433. View "State ex rel. Plunderbund Media v. Born" on Justia Law

Appellant was charged with several offenses stemming from two separate shootings. Appellant was age seventeen when the offenses were committed. After a jury trial, Appellant was convicted of two counts of aggravated murder and sentenced to consecutive terms of life imprisonment without parole. On appeal, Appellant contended that his sentence amounted to cruel and unusual punishment. The court of appeals affirmed, holding (1) Appellant’s sentence was proper under Miller v. Alabama because the sentence imposed in this case was not mandatory but, rather, an exercise of the trial court’s discretion; and (2) the trial court did not violate the Eighth Amendment by failing to consider Appellant’s youth as a mitigating factor in sentencing Appellant. The Supreme Court reversed, holding (1) the Eighth Amendment requires trial courts to consider youth as a mitigating factor when sentencing a child to life without parole for homicide, and the record must reflect that the court specifically considered the juvenile offender’s youth as a mitigating factor at sentencing when a prison term of life without parole is imposed; and (2) because Appellant might not have been given the benefit of the consideration of youth as a mitigating factor, his sentence did not comport with the procedural strictures of Miller. View "State v. Long" on Justia Law

Appellee was charged with criminal child enticement. The complaint alleged that Appellee had asked a child to carry some boxes to his apartment in exchange for money, which conduct allegedly constituted a violation of Ohio Rev. Code 2905.05(A). Appellee filed a motion to dismiss the complaint, asserting that the criminal child enticement statute was unconstitutional because it was overbroad. The trial court agreed and dismissed the complaint. The court of appeals affirmed, holding that section 2905.05(A) was unconstitutionally overbroad. The Supreme Court affirmed, holding that the criminal child enticement statute could not survive constitutional scrutiny due to its overbreadth. View "State v. Romage" on Justia Law

In 2003, Appellant was arrested and charged with the murder of Amber Zurcher. The trial court granted a mistrial on Appellant’s first trial. Several trials followed, and after a fifth trial, another mistrial was declared. When the trial court set a sixth trial date, Defendant moved to dismiss the indictment, arguing that the prosecution was barred by the Double Jeopardy and Due Process Clauses of the U.S. Constitution. The trial court denied the motion. The State moved to dismiss Appellant’s appeal, arguing that the trial court’s denial of Appellant’s motion to dismiss was not a final, appealable order. The court of appeals concluded that, in this situation where there had been multiple mistrials, the order was a final, appealable order. The Supreme Court affirmed, holding that an order denying a motion to dismiss on double-jeopardy grounds is a final, appealable order. Remanded. View "State v. Anderson" on Justia Law

In 2003, Defendant pleaded guilty to aggravation with a firearm specification. The State and Defendant later agreed that Defendant could withdraw his guilty plea and instead plead guilty to aggravated robbery without a firearm specification and to one count of an attempt to have weapons while under a disability. The new agreement decreased Defendant’s sentence by six months. In 2009, Defendant pled guilty to attempted felonious assault. The trial court sentenced Defendant to a term of imprisonment, to run consecutively to the sentence from the 2003 case. Defendant subsequently sought a writ of habeas corpus, arguing that his 2007 plea and resentencing were void and he was therefore entitled to immediate release. The appellate court denied the writ, concluding that Defendant had already unsuccessfully pursued an adequate legal remedy to challenge his 2007 conviction and could not use habeas corpus to try again. The Court of Appeals affirmed, holding that Defendant’s claim was barred by res judicata. View "Smith v. Buchanan" on Justia Law

Appellant pleaded guilty a violation of Ohio’s RICO statute and a predicate offense of trafficking in marijuana. The trial court imposed a six-year sentence for the RICO offense and an eight-year sentence for the trafficking offense, to be served consecutively. On appeal, Appellant asserted that the trial court’s imposition of consecutive prison sentences violated the prohibition against double jeopardy. The court of appeals affirmed Appellant’s separate sentences. Appellant appealed, arguing that the appellate court was required to apply the standard set forth in State v. Johnson in deciding whether the imposition of multiple convictions and sentences for a RICO offense and one or more of its predicate felonies violated the Allied Offenses statute and his rights under the double jeopardy clauses of the state and federal Constitutions. The Supreme Court affirmed, holding that State v. Johnson is not applicable to a RICO violation and that a RICO offense does not merge with its predicate offenses for purposes of sentencing. View "State v. Miranda" on Justia Law