Justia Ohio Supreme Court Opinion Summaries

The Supreme Court denied the petition for a writ of mandamus filed by a group of landowners (“Landowners”) seeking an order compelling the Ohio Department of Natural Resources’ Division of Oil and Gas Resources Management (“the Division”) and its chief to commence appropriation proceedings to compensate Landowners for their land that was included in an oil and gas drilling unit. Landowners objected an an order issued by the chief requiring that a reservoir of oil and gas underlying multiple tracts of land be operated as a unit to recover the oil and gas, arguing that the order amounted to a taking of their property for which they must be compensated. The Supreme Court denied Landowners’ petition for a writ of mandamus, holding that Landowners had an adequate remedy by way of appeal to the county court of common pleas. View "State ex rel. Kerns v. Simmers" on Justia Law

The Supreme Court denied the petition for a writ of mandamus filed by a group of landowners (“Landowners”) seeking an order compelling the Ohio Department of Natural Resources’ Division of Oil and Gas Resources Management (“the Division”) and its chief to commence appropriation proceedings to compensate Landowners for their land that was included in an oil and gas drilling unit. Landowners objected an an order issued by the chief requiring that a reservoir of oil and gas underlying multiple tracts of land be operated as a unit to recover the oil and gas, arguing that the order amounted to a taking of their property for which they must be compensated. The Supreme Court denied Landowners’ petition for a writ of mandamus, holding that Landowners had an adequate remedy by way of appeal to the county court of common pleas. View "State ex rel. Kerns v. Simmers" on Justia Law

A law enforcement agency’s policy that an arrestee’s personal effects must accompany the arrestee to jail, on its own, cannot justify the warrantless retrieval of an arrestee’s personal effects from a location that is protected under the Fourth Amendment. Further, a search of personal effects obtained as a result of following such a policy is not a valid inventory search.The Supreme Court reversed the judgment of the court of appeals, which upheld the trial court’s denial of Defendant’s motion to suppress the evidence found during the search of her purse, and vacated Defendant’s convictions for felony possession of drugs and misdemeanor possession of drug paraphernalia and drug-abuse instruments. The court held (1) the removal of Defendant’s purse from a car in which Defendant was a passenger and the subsequent search of the purse was unlawful; and (2) the exclusionary rule applied to require the suppression of the evidence obtained during the unconstitutional search. View "State v. Banks-Harvey" on Justia Law

In this case alleging breach of contract, fraud, retaliation, constructive discharge, and invasion of privacy, the Supreme Court held (1) in Ohio, punitive damages may not be awarded for a breach of contract; (2) a party to a contract does not breach the implied duty of good faith and fair dealing by seeking to enforce the agreement as written or by acting in accordance with its express terms, and the implied duty is not breached unless a specific obligation imposed by the contract is not met; (3) a release of liability is an absolute bar to a later action on any claim encompassed within it absent a showing of fraud, duress, or other wrongful conduct in procuring it, and a party must prove duress by clear and convincing evidence; (4) the prevention of performance doctrine is not a defense to a release of liability and therefore cannot be asserted as a defense to a release; and (5) a claimant cannot rely on predictions or projections that relate to future performance or that are made to third parties to establish a fraud claim. View "Lucarell v. Nationwide Mutual Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing the petition of Appellant for a writ of habeas corpus. Appellant was granted parole on the condition of “zero tolerance for any positive drug test.” The next month, he tested positive for drug use. After a revocation hearing, Appellant was reincarcerated. Appellant filed a petition for a writ of habeas corpus, claiming violations of his due process, equal protection, and confrontation rights. The court of appeals concluded that habeas corpus was not available to grant the relief Defendant sought. The Supreme Court agreed, holding that Defendant failed to state a proper claim in habeas corpus. View "State ex rel. Womack v. Sloan" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing the petition of Appellant for a writ of mandamus against the Ohio Adult Parole Authority (APA). In his petition, Appellant argued that he had received multiple punishments for the same parole violation in violation of the Double Jeopardy Clause. The court of appeals dismissed the action, ruling that Appellant ha not received multiple punishments and that Appellant had failed to demonstrate any constitutional injury. The Supreme Court denied Appellant’s motion for leave to supplement his reply brief and affirmed the judgment of the court of appeals, holding (1) double jeopardy protections were not violated by the sanctions imposed for Appellant’s parole violation; and (2) the APA did not violate Appellant’s due process rights by holding a parole hearing after his parole officer had imposed sanctions against him. View "Clark v. Adult Parole Authority" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals that affirmed Defendant’s felonious assault conviction for knowingly engaging in sexual conduct with his girlfriend without disclosing to her that he had tested positive as a carrier of the human immunodeficiency virus (HIV), in violation of Ohio Rev. Code 2903.11(B)(1). On appeal, Defendant argued that section 2903.11(B)(1) (1) is a content-based regulation that compels speech in violation of the First Amendment, and (2) violates the Equal Protection Clause of the state and federal Constitutions because there is no rational basis for a distinction between HIV positive individuals and individuals with other infectious diseases such as Hepatitis C or between the methods of transmitting HIV. The Supreme Court disagreed, holding (1) the statute regulates conduct, not speech, and therefore does not violate the First Amendment; and (2) the statute does not violate constitutional equal protection guarantees because it is rationally related to the state’s legitimate interest in preventing the transmission of HIV to sexual partners who may not be aware of the risk. View "State v. Batista" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing the petition of Appellant for a writ of habeas corpus. Appellant was charged with drug trafficking and drug possession while on parole for an earlier offense. The Ohio Adult Parole Authority (APA) found that Appellant violated the terms of his parole by having illegal drugs under his control and ordered him to serve the remainder of his original maximum sentence. The State subsequently dismissed the drug charges for insufficient evidence. In his habeas petition, Petitioner argued that the APA violated his due process rights by finding a parole violation based on insufficient evidence. The court of appeals dismissed the petition on several grounds. The Supreme Court affirmed, holding that the court of appeals did not err in determining that Appellant’s petition (1) did not comply with the mandatory filing requirements of Ohio Rev. Code 2969.25(C) and 2725.04(D); (2) was not properly captioned in accord with Ohio R. Civ. P. 10(A); and (3) failed to state a claim for relief in habeas corpus. View "Greene v. Turner" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that the exclusionary rule is not the appropriate remedy when police executing a valid search warrant violate the requirements of the knock-and-announce statute, Ohio Rev. Code 2935.12.The court of appeals reversed the judgment of the trial court granting Defendants’ motion to suppress all evidence obtained during the search of an apartment. The trial court found that police had violated section 2935.12 without any exigent circumstances justifying the violation. The Supreme Court agreed with the appellate court and remanded the cause to the trial court for further proceedings, holding that the exclusion of evidence is not the proper remedy for a violation of the knock-and-announce statute. View "State v. Bembry" on Justia Law

Under Ohio law, an employer may appeal a determination by the Industrial Commission that an employee has the right to participate in the workers’ compensation fund, and although the employer files the appeal in the common pleas court, the employee is the plaintiff. At issue was whether a provision enacted in 2006 allowing an employee to dismiss an employer-initiated appeal only with the consent of the employer is constitutional.The court of appeals in this case affirmed the trial court’s judgment declaring the so-called “consent provision” of Ohio Rev. Code 4123.512(D) unconstitutional. The trial court concluded that the consent provision was unconstitutional on the grounds of due process and equal protection and violates the doctrine of separation of powers. The Supreme Court reversed, holding that the consent provision of section 4123.512(D) does not improperly conflict with the Ohio Rules of Civil Procedure, nor does it violate the equal-protection or due-process guarantees of the federal and state Constitutions. View "Ferguson v. State" on Justia Law