Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions and sentence for three counts of aggravated murder, six counts of aggravated robbery and other crimes and his sentence of life in prison, holding that a trial court errs in its evaluation of a defendant's lack of remorse when it considers that defendant's decision to waive allocution and remain silent at sentencing if the defendant exercised his right to a jury trial.Specifically, the Supreme Court held (1) the lower courts did not err in determining that Defendant did not waive his attorney-client privilege with regard to direct communications with his attorney; (2) even if this case presented circumstances in which the attorney-client privilege yielded to Defendant's right to confrontation, any error was not prejudicial; and (3) while the trial court erred in considering Defendant's decision to waive allocution and remain silent in determining whether he lacked remorse, the error was not prejudicial. View "State v. Brunson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the juvenile court to transfer Appellant to adult court, holding that that court's decision to transfer Appellant to adult court was not supported by a preponderance of the evidence and that the juvenile court abused its discretion by relinquishing jurisdiction.After the juvenile court transferred jurisdiction over Appellant to the general division a jury found Appellant guilty of aggravated murder and murder for a killing that occurred when he was fourteen years old. The court of appeals affirmed the conviction, concluding that the juvenile court did not violate Appellant's constitutional right to due process by transferring his case to the adult court. The Supreme Court reversed, holding (1) the standard of proof applicable to discretionary-bindover proceedings is a preponderance of the evidence, and the state need not produce affirmative evidence of nonamenability; (2) a juvenile court need not consider all potential juvenile dispositions when balancing the factors weighing in favor of and against transfer; and (3) the juvenile court improperly relinquished jurisdiction in this case. View "State v. Nicholas" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated murder and his sentence of death, holding that, while error occurred in this case in the form of repetitive crime scene photos, the prosecutor's misstatements, and sentencing opinion errors, none of the errors resulted in prejudicial error.After a jury trial, Defendant was found guilty of the aggravated murders of his four-year-old daughter, C.D., and her mother, Nicole Duckson, with accompanying death-penalty specifications. The court sentenced Defendant according to the jury's recommendation of a sentence of death for the aggravated murder of C.D. The court then sentenced Defendant to life without parole for the aggravated murder of Nicole. The Supreme Court affirmed but remanded the case, holding (1) Defendant received a fair trial, and none of the errors in this case, when considered either individually or cumulatively, resulted in prejudicial error; (2) the overwhelming evidence established Defendant's guilt; and (3) the case must be remanded for the trial court to issue a nunc pro tunc entering confirming the September 14, 2019 judgment entry and the September 16, 2019 entry to the sentence that was imposed at the sentencing hearing. View "State v. Garrett" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions and remanding the matter for a new trial, holding that the trial court did not violate Defendant's Sixth Amendment right to a public trial by partially limiting access to the courtroom after an altercation disrupted court proceedings.Defendant was indicted on two counts of murder. During a recess on the third day of trial, some of the people attending the trial were involved in an altercation outside the courtroom, which resulted in the court limiting attendees to only immediate family members. Defendant was subsequently found guilty of murder as a result of felonious assault. The court of appeals reversed, ruling that the trial court had committed structural error by failing to provide sufficient justification for the partial closure of the courtroom. The Supreme Court reversed, holding that a public trial violation occurred in Defendant's trial but that the error did not rise to the level of a plain error that must be corrected. View "State v. Bond" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's petitions for postconviction relief challenging his convictions in a rape case and a jail case, holding that there was no error.After a jury trial, Appellant was convicted of rape and kidnapping. While he was being held in jail on the rape charges, Appellant and two other inmates attacked one of their cellmates. A jury found Appellant guilty of felonious assault and kidnapping for the attack. Appellant later filed petitions for postconviction relief challenging his convictions in both cases. The trial court denied relief. The Supreme Court affirmed, holding (1) postconviction claims alleging a denial of the constitutional right to effective assistance of counsel are not procedurally barred if they cannot meaningfully be reviewed without resorting to evidence outside the trial record; and (2) all of Appellant's claims were either barred by res judicata or failed to set forth a substantive claim for relief. View "State v. Blanton" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the trial court's denial of Defendant's motion to dismiss the criminal case against him based on an alleged violation of his statutory speedy-trial right, holding that the State did not violate Defendant's speedy-trial rights.The day before trial was set to begin, Defendant moved to dismiss the case base on an alleged violation of his statutory right to a speedy trial. The trial court denied the motion. Thereafter, Defendant entered a plea of no contest to a single felony count. The court of appeals affirmed. The Supreme Court affirmed, holding that there was no violation of Defendant's statutory speedy-trial rights in this case. View "State v. Belville" on Justia Law

The Supreme Court denied a writ of mandamus compelling Ohio Secretary of State Frank LaRose to allow Relator to appoint election observers to inspect the counting of votes and compelling LaRose to provide election observers with copies of all software, hardware, and source codes installed on any automatic vote-tabulating machine, holding that Relator was not entitled to the writ.Relator, an independent candidate for Ohio Secretary of State on the November 8, 2022 general-election ballot, brought this expedited election case (1) asserting that Ohio Rev. Code 3505.21, which governs the appointment of election observers, violates constitutional equal protection guarantees because it restricts certified independent candidates' ability to appoint election observers; and (2) asking that tabulating-machine software be "open or unlocked" so that observers "may inspect [the machines] to the source code level[.]" The Supreme Court denied the writ, holding that there was no basis for a writ of mandamus to issue. View "State ex rel. Maras v. LaRose" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated murder with death specifications and her sentence of death, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant raised sixteen propositions of law. The Supreme Court rejected each proposition of law, holding, among other things, that (1) there was no prejudicial error in the trial court's evidentiary rulings; (2) Defendant was not entitled to relief on his ineffective assistance of counsel claims; (3) although significant mitigating factors existed, the aggravating circumstances outweighed the mitigating factors beyond a reasonable doubt; and (4) the death sentence was appropriate and proportionate. View "State v. Drain" on Justia Law

The Supreme Court reversed the judgment of the court of appeals determining that the evidence should have been suppressed in the underlying criminal case based on a statutory violation, holding that there was no violation of Defendant's Fourth Amendment rights in this case.While Defendant was serving community control, his probation officer conducted a random home-check on Defendant, searched his cell phone, and discovered child pornography. Defendant moved to suppress the uncovered evidence on the grounds that the suspicion-less search violated the Fourth Amendment. The district court denied the suppression motion. The court of appeals reversed, concluding that the search violated Ohio Rev Code 2951.02(A)'s requirement that a probation officer may conduct a search only when there are "reasonable grounds to believe" that a probationer is violating the law or conditions of control. The Supreme Court reversed, holding (1) the probation officer exceeded the scope of her authority when she searched Defendant's cell phone without reasonable grounds to believe that he had violated the law or the conditions of probation; and (2) because there was no constitutional violation, there was no basis to exclude the evidence obtained as a result of the search. View "State v. Campbell" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the order of the trial court ordering forfeiture of Appellant's 2014 Chevrolet Silverado, holding that there was no equal protection violation and that, as applied to Appellant, the vehicle forfeiture did not violate the Excessive Fines Clause of the Eighth Amendment.Appellant entered a plea of no contest to one charge of operating a vehicle while intoxicated (OVI). Because Appellant had two prior OVI convictions within the preceding ten years, his vehicle was seized pending the completion of the proceedings. After a forfeiture hearing held pursuant to Ohio Rev. Code 4503.234 the trial court ordered Appellant to forfeit his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the statutory classification contained in Ohio Rev. Code 4511.19(G)(1)(c)(v) does not violate constitutional equal protection guarantees; and (2) the forfeiture of Appellant's vehicle was not grossly disproportional and was thus not unconstitutional as applied to Appellant. View "State v. O'Malley" on Justia Law