Justia Ohio Supreme Court Opinion Summaries

Plaintiff filed a class action complaint alleging that Federal National Mortgage Association (Fannie Mae) failed timely to record in the appropriate county recorder’s office the satisfaction of her residential mortgage within ninety days after payoff, as required by Ohio Rev. Code 5301.36(B). After the class was certified, the Federal Housing Finance Agency (FHFA) issued a cease-and-desist order (consent order) to Fannie Mae. Fannie Mae moved to dismiss for lack of subject matter jurisdiction. The trial court dismissed the complaint for lack of subject matter jurisdiction. The court of appeals reversed, concluding that the FHFA consent order did not divest the trial court of jurisdiction. The Supreme Court affirmed, holding (1) the consent order did not preclude the trial court from exercising jurisdiction under 12 U.S.C. 4635(b), the federal statute governing judicial review of FHFA orders; but (2) 12 U.S.C. 4617(j)(4) barred the trial court from ordering Fannie Mae to pay damages under section 5301.36(C) while Fannie Mae is under FHFA’s conservatorship. View "Radatz v. Fed. Nat’l Mortgage Ass’n" on Justia Law

Named Plaintiffs filed an amended class-action complaint challenging the city of Cleveland’s imposition of fines against vehicle lessees. The trial court granted Cleveland’s motion for judgment on the pleadings, concluding that Plaintiffs had waived the right to pursue judicial remedies by paying their fines and failing to appeal their citations. The trial court also denied Plaintiffs’ class-certification motion. The court of appeals reversed and remanded. On remand, the trial court granted partial summary judgment for Plaintiffs. The court also granted class certification. Cleveland appealed the class certification order, arguing that res judicata precluded class relief. The court of appeals affirmed, concluding that Plaintiffs’ failure to appeal their traffic violations through Cleveland’s administrative process did not bar them from pursuing equitable and declaratory relief in the trial court. The Supreme Court vacated in part the judgment of the court of appeals, holding that the court of appeals erred in deciding that res judicata barred Plaintiffs’ claims, in the absence of a final, appealable order from the trial court addressing that question. Remanded. View "Lycan v. Cleveland" on Justia Law

This appeal arose from two related class-action lawsuits that were first brought by Appellees almost fifteen years ago. Appellees sought damages from Appellants, Ganley Chevrolet and Ganley Management Company, as well as declaratory and injunctive relief, alleging violations of the Ohio Consumer Sales Practices Act (OCSPA). The trial court eventually certified a class of plaintiffs and ruled that all class members could recover damages. The trial court then ruled that Appellants violated the OCSPA and awarded damages to each class member. The appellate court affirmed the trial court’s order certifying the class without squarely addressing Appellants’ claim that there was no showing that all class members had suffered damages. The Supreme Court reversed the judgment of the court of appeals and vacated the trial court’s order certifying the class, holding (1) all members of a plaintiff class must have suffered injuries as a result of the conduct challenged in the suit; and (2) because the class certified in this case included plaintiffs whose damages were inchoate, the class as certified was inconsistent with the law. View "Felix v. Ganley Chevrolet, Inc." on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, aggravated robbery, and having weapons under disability. Prior to trial, Defendant filed a suggestion of incompetence to stand trial and a plea of not guilty by reason of insanity. A psychologist conducted a court-ordered evaluation on the issues of Defendant’s competency and sanity. Defendant later withdrew the defenses. On appeal, Defendant argued that the trial court violated his Fifth Amendment privilege against self-incrimination when it allowed the psychologist to testify during trial. The court of appeals reversed Defendant’s convictions for aggravated murder and aggravated robbery, concluding that Ohio Rev. Code 2945.371(J) prohibits the use of statements made by a defendant in a psychiatric evaluation against the defendant on the issue of guilt in a criminal action. The Supreme Court affirmed, holding (1) when a defendant asserts a mental-capacity defense, resulting in the court ordering a psychiatric evaluation, but then the defendant wholly abandons the defense, a psychologist’s testimony regarding the defendant’s feigning of mental illness during the court-ordered evaluation is inadmissible in the state’s case-in-chief pursuant to section 2945.371(J); and (2) the trial court’s admission of the psychologist’s testimony in this case was not harmless error. View "State v. Harris" on Justia Law

William Glick filed a class action suit against Raymond Wohl, in his official capacity of the clerk of the municipal court, among other defendants, seeking declaratory and equitable relief related to Glick's municipal court sentences he alleged to be void for imposing unlawfully excessive court costs. The common pleas court determined that Glick’s class action against Wohl was viable, declared that multiple costs assessed against Glick as part of his sentence were unlawful, and held that Glick and other class members who had been assessed unlawful costs were owed a refund. The court of appeals reversed, concluding that the class action was not viable, and remanded for entry of summary judgment in favor of Wohl. The Supreme Court affirmed, holding (1) the relief requested by Glick in his class action was in substance a request to vacate a portion of a judgment of the municipal court; and (2) because a court of common pleas has no power to vacate an order rendered by a municipal court, summary judgment should have been granted in favor of Wohl. Remanded. View "Lingo v. State" on Justia Law

Michael Cullen sued State Farm Mutual Automobile Insurance Company requesting class certification and a declaratory judgment that State Farm failed to disclose all benefits available to policyholders who made claims for damaged windshields. The trial court certified the class, concluding that Cullen and the class satisfied the requirements of Ohio R. Civ. P. 23. The court of appeals affirmed the order certifying the class but reversed the portion of the decision defining the class and remanded with instructions to the trial court to redefine it. The Supreme Court reversed, holding (1) because the declaratory relief at issue here was incidental to an individualized claim for monetary damages, Cullen failed to meet the requirement for certification set forth in Rule 23(B)(2); and (2) Cullen failed to prove that this action satisfied Rule 23(B)(3) because individual questions predominated over the questions common to the proposed class. Remanded. View "Cullen v. State Farm Mut. Auto. Ins. Co." on Justia Law

Defendant was charged with violating Ohio Rev. Code 4301.69(A), which prohibits the sale of beer to an underage person. At Defendant's trial, the State had difficulty proving what Defendant sold to an informant was beer as defined by statute. The court then took judicial notice that Bud Light was, in fact, beer. Defendant was convicted as charged. The court of appeals reversed and ordered a new trial, concluding that the trial court erred in taking judicial notice of a fact - the alcohol content by volume of Bud Light - that was not something that was "generally known." The Supreme Court reversed and vacated Defendant's conviction, holding that because there was no evidence admitted on the statutory element of the alcohol content of the substance sold by Defendant to the informant, there was insufficient evidence for a conviction, and double jeopardy barred a retrial. View "State v. Kareski" on Justia Law

In 2005, a limited liability company and its owners (plaintiffs), on behalf of other similarly situated telephone customers, filed a complaint seeking to certify a class action lawsuit against United Telephone Company of Ohio (UTO), which provided Plaintiffs with telephone service. Plaintiffs claimed that their phone bills from UTO contained unauthorized charges from third parties. The trial court ultimately denied Plaintiffs' amended motion for class certification. The court of appeals reversed. The Supreme Court reversed and reinstated the order of the trial court, holding (1) a trial court must conduct a rigorous analysis to ensure the prerequisites of Ohio R. Civ. P. 23, under which plaintiffs must establish seven prerequisites in order to certify a class action, are satisfied; and (2) even though the trial court's consideration of the merits in this case was improper, its order denying certification of the class was correct because Plaintiffs' proposed amended class did not satisfy the prerequisites of Rule 23. View "Stammco, LLC v. United Tel. Co. of Ohio" on Justia Law