Justia Ohio Supreme Court Opinion Summaries

In 2012, a principal of Lipson O’Shea Legal Group made a request for records from Cuyahoga County Board of Health (Cuyahoga County BOH) seeking documentation of homes in the County where a minor child was found to have elevated blood lead levels. Cuyahoga County BOH sought a declaratory judgment with respect to its obligations to maintain the confidentiality of the records sought by Lipson O’Shea. The trial court granted summary judgment for Cuyahoga County BOH, concluding that the release of the records was prohibited by Ohio Rev. Code 3701.01, which exempts from disclosure certain health information if the information could be used to reveal the individual’s identity. The court of appeals reversed, declaring that, rather than withholding all records, Cuyahoga County BOH must examine each document, redact any protected health information, and release any remaining unprotected information not otherwise excepted. The Supreme Court affirmed, holding that some of the information in the requested records prepared by the Cuyahoga County BOH is not protected health information, and therefore, it cannot be said that all of the information responsive to the request is protected. View "Cuyahoga County Bd. of Health v. Lipson O'Shea Legal Group" on Justia Law

Plaintiffs, former correctional institution employees and a labor union, filed this action against numerous government Defendants, alleging that 2011 Am.Sub.H.B. No. 153, the budget bill for the 2012-2013 biennium, violates the Ohio Constitution. H.B. 153 modified prior law governing contracts for the private operation and management of a state correctional institution in several ways. The court of common pleas granted Defendants’ motion to dismiss, concluding (1) the court lacked jurisdiction to determine whether employees of privately owned or operated prisons were employees, as defined by Ohio Rev. Code 4117.01(C); and (2) the court had jurisdiction over the constitutional challenges to H.B. 153, but Plaintiffs failed to state a claim that H.B. 153 was unconstitutional. The court of appeals reversed in part and ordered the trial court to hold an evidentiary hearing to determine whether H.B. 153 violates the one-subject rule in Ohio Const. art. II, 15(D). The Supreme Court affirmed in part and reversed in part, holding (1) H.B. 153 is constitutional; and (2) the State Employee Relations Board has exclusive jurisdiction to determine public-employee status under section 4117.01(C). View "State ex rel. Ohio Civil Serv. Employees Ass’n v. State" on Justia Law

This appeal involved Defendant’s motion to suppress evidence of a gun that was found in a search of a car legally parked on a public street that Defendant was sitting in just before his arrest on a warrant for domestic violence. After Defendant was arrested, an officer conducted an inventory search of the car, during which he found a handgun. The district court denied Defendant’s motion to suppress, concluding that there was probable cause to arrest Defendant based on the domestic-violence warrant and that, pursuant to that arrest, the inventory search of the car prior to towing was proper. The Supreme Court reversed, holding that the warrantless inventory search of the lawfully parked vehicle in this case was unreasonable under the Fourth Amendment to the United States Constitution and Ohio Const. art. I, 14. View "State v. Leak" on Justia Law

Defendant pled guilty to one count of unlawful sexual conduct with a minor who was over thirteen but less than sixteen years of age. Defendant, who was twenty-one years old when he committed the offense, was designated a Tier II sex offender/child-victim offender and was required to register with the county sheriff and to verify his residence address every 180 days for twenty-five years. Defendant appealed, arguing that the Tier II sex-offender requirements imposed upon him violated the Eighth Amendment’s prohibition against cruel and unusual punishment. The court of appeals affirmed. The Supreme Court affirmed, holding that the registration and address-verification requirements for Tier II offenders under Ohio Rev. Code 2950 do not constitute cruel and unusual punishment. View "State v. Blankenship" on Justia Law

Defendant was found guilty of two counts of aggravated murder and six counts of attempted murder. Defendant was sentenced to death. On appeal, the Supreme Court reversed Defendant’s convictions, vacated the death sentence, and remanded for a new trial. After a new jury was convened, Defendant was convicted on all charges and specifications and again sentenced to death. The Supreme Court affirmed the convictions and sentence of death, holding (1) no error occurred in the selection and removal of jury members; (2) the trial court did not make erroneous evidentiary rulings that denied him a fair trial; (3) the trial court did not err in its instructions to the jury; (4) the evidence was sufficient to support the convictions; (5) no prejudicial error occurred during the penalty phase; (6) the prosecutor did not commit misconduct during either the guilt phase or penalty phase of trial; (7) Defendant’s counsel provided effective assistance during both phases of trial; and (8) Defendant’s death sentence was appropriate and proportional. View "State v. Dean" on Justia Law

After a jury trial, Appellant was convicted of aggravated murder. The trial court sentenced Appellant to death. The Court of Appeals affirmed the conviction and sentence. The Supreme Court affirmed the conviction for aggravated murder but vacated the sentence of death, holding (1) the trial court did not commit prejudicial error in its pretrial rulings or violate Appellant’s right to a speedy trial or fair trial; (2) there was no prejudicial error or violation of Appellant’s constitution rights regarding jury selection; (3) the trial court did not err in denying Appellant’s motion to suppress; (4) Appellant was not prejudiced by prospective juror misconduct, and the trial court did not err in denying Appellant’s motion for a mistrial based on statements made by a witness; (5) Appellant did not receive ineffective assistance of counsel; (6) the jury was properly instructed; but (7) there was not sufficient evidence to support the finding on the capital specification, and therefore, the evidence was insufficient to support the death sentence. Remanded for a new sentencing hearing. View "State v. Adams" on Justia Law

Appellee was found guilty of murder and sentenced to death. The Supreme Court reversed. After a retrial, Defendant was convicted of aggravated murder and sentenced to death. The court of appeals affirmed the conviction and death sentence. After a “long and complex history,” a federal district court ultimately granted a writ of habeas corpus, finding that Appellee was denied the right to due process as interpreted in Brady v. Maryland. New proceedings subsequently commenced in the trial court. The trial court granted Appellee’s motion to dismiss, concluding that because of the prejudice suffered by Appellee in light of the State’s “egregious prosecutorial misconduct” and the Brady violations in his two prior trials, Appellee could not receive the fair trial he was entitled to. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court acted unreasonably, unconscionably, and arbitrarily when it found that it was impossible for Appellee to receive a fair trial without first giving the parties an opportunity to develop the record. Remanded to the trial court with instructions to proceed to trial. View "State v. Keenan" on Justia Law

Defendant was stopped by a Lake Township patrol officer and canine handler for a marked lane violation on an interstate highway. The officer walked her dog around the vehicle Defendant was driving, leading to the discovery oxycodone tablets and a baggie of marijuana. It is undisputed that the township police officer exercised law-enforcement powers not granted to township police officers. Defendant moved to suppress the evidence obtained from the traffic stop, but the court denied it, concluding that the officer had probable cause to stop Defendant for a marked lane violation. Defendant was subsequently convicted. Defendant appealed, asserting that the officer lacked statutory authority to stop him for a marked lane violation on an interstate highway, and therefore, the stop and subsequent arrest and search were unconstitutional. The appellate court reversed Defendant’s conviction, concluding that the stop violated the Ohio Constitution because the marked lane violation occurred outside the officer’s territorial jurisdiction. The Supreme Court affirmed, holding that because the officer acted without authority to stop Defendant for a minor misdemeanor traffic offense on an interstate highway, the traffic stop, the arrest, and the search were unreasonable and violated Ohio Const. art. I, 14. View "State v. Brown" on Justia Law

After a jury trial, Defendant was found guilty of two counts of retaliation, criminal damaging, vandalism, criminal trespass, possessing criminal tools, and ten counts of pandering. Defendant appealed, arguing that the trial court erred in denying his motion to suppress information found on his computer. The court of appeals affirmed, concluding that the affidavit provided a substantial basis for concluding that evidence of criminal activity would be found there. The Supreme court reversed, holding (1) the search warrant was not supported not supported by probable cause, and (2) the search warrant violated the Fourth Amendment requirement of particularity, thereby rendering invalid the search of Defendant’s computer. View "State v. Castagnola" on Justia Law

Employee filed a charge with the Ohio Civil Rights Commission contending that her employment by Employer had been terminated because she became pregnant. The Commission found that Employer had participated in a discriminatory practice in violation of Ohio Rev. Code 4112. Employer filed a petition for judicial review pursuant to Ohio Rev. Code 4112.06. The common pleas court granted the Commission’s motion to dismiss, concluding that the petition for review was not timely served on the parties because Employer failed to properly initiate service by the clerk within thirty days of the date the Commission’s order was filed. The Court of Appeals reversed, holding that Employer had one year to obtain service of a petition to review an order of the Commission. The Supreme Court affirmed, holding (1) the Rules of Civil Procedure apply to proceedings initiated pursuant to section 4112.06; and (2) therefore, a petition to review an order of the Commission must be served by a clerk of courts on all parties who appeared before the Commission and on the Commission itself within one year of the date the petition was filed as required by Ohio R. Civ. P. 3(A). View "Hambuechen v. 221 Market North, Inc." on Justia Law