Justia Ohio Supreme Court Opinion Summaries

Michael Jones was convicted by a jury of ten drug-trafficking and drug-possession charges. Before the trial, Jones filed a motion to suppress evidence seized from a safe in a house, arguing that the consent to search was invalid and the search warrant for the safe was insufficient. The trial court denied the motion and sentenced Jones to an aggregate prison term of 22 to 24.5 years.Jones appealed to the First District Court of Appeals, arguing ineffective assistance of counsel for not challenging the evidence as coerced and the protective sweep as unconstitutional. The appellate court agreed, finding that Jones's trial counsel had a reasonable basis to challenge the consent and the protective sweep. The court concluded that the failure to raise these arguments constituted deficient performance and prejudiced Jones. The appellate court ordered a limited remand for Jones to file a new motion to suppress and for the trial court to hold a suppression hearing, staying the consideration of Jones’s remaining assignments of error.The Supreme Court of Ohio reviewed the case and determined that it had jurisdiction under Article IV, Section 2(B)(2) of the Ohio Constitution and R.C. 2505.03(A). The court found that the First District did not comply with App.R. 12(A)(1)(a) and (c) because it did not affirm, modify, or reverse the trial court’s judgment and did not decide all assignments of error. The Supreme Court reversed the judgment of the First District, vacated its entry ordering limited remand, and remanded the case to the First District to enter a judgment that complies with App.R. 12. View "State v. Jones" on Justia Law

The case involves Damon L. Taylor, who was charged with felony murder in the adult court after the juvenile court found probable cause to believe that Taylor was complicit in a murder. The adult court convicted Taylor of felony murder, but the Tenth District Court of Appeals vacated the conviction, arguing that the adult court lacked jurisdiction to convict Taylor of felony murder as the juvenile court had not found probable cause for that specific offense. The appellate court also ruled that Taylor's statements to the police should have been suppressed as his Sixth Amendment right to counsel had been violated.The Supreme Court of Ohio disagreed with the appellate court's decision. The Supreme Court held that the adult court did have jurisdiction over the felony-murder charge against Taylor. The court reasoned that the felony-murder charge was rooted in the same acts and events as the complicity-to-commit-murder charge, which was the subject of the juvenile complaint. Therefore, under former R.C. 2151.23(H), the adult court had jurisdiction over the felony-murder charge.Regarding Taylor's Sixth Amendment right to counsel, the Supreme Court held that this right did not attach until a criminal prosecution had commenced, which occurred after the police interrogated Taylor. Therefore, the state did not violate Taylor's Sixth Amendment right to counsel when it interviewed him in the absence of his attorney. Even if the Sixth Amendment right to counsel had attached, Taylor validly waived it when he relinquished his Fifth Amendment right to counsel after he received the Miranda warnings.The Supreme Court reversed the judgment of the Tenth District Court of Appeals and remanded the matter to that court for further proceedings. View "State v. Taylor" on Justia Law

The case revolves around Deonta Boyd, an inmate at the Richland Correctional Institution, who pleaded guilty in 2006 to aggravated murder with a firearm specification, felonious assault, and aggravated burglary. The trial court accepted Boyd's pleas and sentenced him to life imprisonment with parole eligibility after 41 years. Boyd did not appeal his convictions or sentence but has attempted unsuccessfully to withdraw his guilty pleas multiple times. In March 2023, Boyd filed a complaint for a writ of prohibition, claiming that the trial court violated his rights under the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution and their counterparts in the Ohio Constitution. He alleged that the trial court failed to inform him that he was waiving his constitutional right to compulsory process at the 2006 plea hearing.The Sixth District Court of Appeals dismissed Boyd's prohibition complaint, holding that Boyd could have challenged any defect in the plea colloquy on direct appeal and that any issue concerning the trial court’s alleged failure to advise him of his right to compulsory process is therefore barred by res judicata. Boyd appealed the dismissal of his complaint.The Supreme Court of Ohio affirmed the Sixth District Court of Appeals' judgment. The court found that Boyd had adequate remedies in the ordinary course of the law to raise his claim, including a direct appeal, a petition for postconviction relief, and a motion to withdraw his guilty pleas. The court also found that the trial court did not patently and unambiguously lack subject-matter jurisdiction to convict him. Therefore, Boyd was not entitled to a writ of prohibition, and the Sixth District correctly dismissed the prohibition action. View "State ex rel. Boyd v. Tone" on Justia Law

The case revolves around a criminal defendant's right to confront the witnesses against him under the Confrontation Clause of the Sixth Amendment to the United States Constitution. The defendant, Eli Carter, was found guilty of having sexual relations with his adopted daughter. He argued that his right to face-to-face confrontation was violated because the trial court allowed a witness to testify remotely via video conference.The trial court had allowed the remote testimony due to the witness's unavailability to testify in person due to unpredictable winter weather and uncertain airline schedules. The court also noted the state's identification of the witness as important and found his testimony relevant and admissible. The defendant appealed this decision, arguing that the remote testimony violated his constitutional right to confront the witnesses against him.The Third District Court of Appeals rejected the defendant's arguments and affirmed the trial court's judgment. The court of appeals noted that the trial court had found that airline-labor shortages and other causes were creating unprecedented travel delays. The court further stated that even if it were to assume that the possibility of inclement weather was insufficient to warrant an exception for the witness's video testimony, the trial court's determinations were justified on a case-specific finding based on an important public policy involving the COVID pandemic.The Supreme Court of Ohio agreed that the trial court erred by allowing the remote testimony. The court held that the trial court's generalized concerns about COVID-19 risks and travel delays did not constitute a "case-specific finding of necessity," sufficient to abridge the defendant's right to face-to-face confrontation. However, the court also concluded that the trial court's error was harmless given the remaining evidence at trial. The court found that there was no reasonable possibility that the witness's testimony contributed anything to the jury's findings of guilt that it could not have gleaned from other witnesses. Therefore, the court affirmed the judgment of the Third District Court of Appeals, albeit on different grounds than those relied upon by that court. View "State v. Carter" on Justia Law

During the COVID-19 pandemic, the Ohio General Assembly passed a temporary law (H.B. 197) stating that for a limited time, Ohio workers would be taxed by the municipality that was their “principal place of work” rather than the municipality where they actually performed their work. Josh Schaad, who primarily worked from his home in Blue Ash during the pandemic, challenged this law after his employer withheld municipal taxes from his wages and forwarded them to Cincinnati, the location of his employer's business. Schaad's principal argument was that the Due Process Clause of the Fourteenth Amendment to the United States Constitution forbids an Ohio municipality from taxing a nonresident for work performed outside of that municipality. The Supreme Court of Ohio rejected Schaad's argument and affirmed the judgment of the First District Court of Appeals, holding that the Due Process Clause did not prohibit the General Assembly from directing that an Ohio citizen pay taxes to the municipality where the employee’s principal place of work was located rather than to the subdivision of the state where the employee actually worked. The court also held that the General Assembly's power to pass emergency legislation did not expand its substantive constitutional powers. View "Schaad v. Alder" on Justia Law

In this case addressing the General Assembly districting plan adopted by the Ohio Redistricting Commission in September 2023 the Supreme Court granted motions to dismiss brought by Petitioners, who filed motions for leave to file objections instanter to the plan and denied motions to vacate and for leave to file objections, holding that dismissal was warranted.The Commission adopted a new redistricting plan in September 2023 by a unanimous vote. Petitioners moved for leave to file objections. Respondents, members of the Commission, moved to dismiss the cases and to vacate the court's orders declaring the districting plan adopted by the General Assembly in September 2021 as unconstitutional. The Supreme Court granted the motions to dismiss, denied the motions to vacate as moot, and denied the motions for leave to file objections to the September 2023 plan, holding that now that the Commission has adopted a plan with bipartisan support, the facts before the Court bore no resemblance to the allegations in Petitioners' complaints. View "League of Women Voters of Ohio v. Ohio Redistricting Comm'n" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition ordering the trial court to vacate his criminal sentence, holding that Appellant was not entitled to a writ of mandamus or prohibition.Appellant was convicted of escape, retaliation, and other offenses and sentenced to 26.5 years in prison. Appellant later brought the current action seeking writs of prohibition and mandamus ordering the trial court to vacate his sentencing entries and to grant any other relief to which he was "entitled." The court of appeals dismissed the complaint for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law through direct appeal to raise his claim that the Sixth Amendment requires that a defendant be expressly informed of his right to counsel at each critical stage of the proceeding and that the trial court's failure to do so in his case rendered his sentence void. View "State ex rel. Rarden v. Butler County Common Pleas Court" on Justia Law

In this case concerning how an Ohio prisoner is to enforce his constitutional right to a speedy trial on an untried indictment the Supreme Court held that a prisoner satisfies the "causes to be delivered" requirement of Ohio Rev. Code 2941.401 when he delivers the written notice and the request to the warden where he is imprisoned, even if the warden fails to deliver the notice and the request to the prosecuting attorney or the appropriate court.Appellant, who was indicted on counts of aggravated robbery and robbery, moved to dismiss the indictment on speedy-trial grounds. The trial court granted the motion, concluding that Appellant had strictly complied with section 2941.401 when he provided written notice of his place of imprisonment and a request for a final disposition and that the 180-day speedy trial time was not tolled by the warden's failure to comply with his duty to send out Appellant's written notices and requests to the prosecuting attorney or the appropriate court. The court of appeals reversed, concluding that Appellant had not strictly complied with the requirements of the statute. The Supreme Court reversed, holding that Appellant caused to be delivered his written notice and request for final disposition under the statute when he provided them to the warden. View "State v. Williams" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions for felony charges stemming from an inventory search of an impounded truck that Defendant was driving when he was pulled over by a law enforcement officer, holding that the search was reasonable and lawful under the Fourth Amendment.Law enforcement performed an inventory search as to the truck at issue and found a handgun in the truck's right door panel. After Defendant unsuccessfully moved to suppress the evidence of the gun the trial court found him guilty. The court of appeals reversed, holding that the search was not reasonable under the Fourth Amendment because the state's evidence was insufficient. The Supreme Court reversed, holding that the inventory search was lawful. View "State v. Toran" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting summary judgment in favor of the Hocking County Common Pleas Court and Judge Dale Crawford in Appellant's action for writs of mandamus and prohibition, holding that the court of appeals correctly determined that the doctrine of res judicata barred Appellant's claims.Appellant was found guilty of assaulting a peace officer. The court of appeals affirmed. About seven years later, Appellant filed a complaint for writs of mandamus and prohibition alleging that the trial court deprived her of her constitutional right to counsel and lacked jurisdiction to hold the sentencing hearing. The court of appeals concluded that the doctrine of res judicata barred Appellant's claims. The Supreme Court affirmed, holding that the court of appeals correctly determined that res judicata barred this mandamus and prohibition action. View "State ex rel. Ogle v. Hocking County Common Pleas Court" on Justia Law