Justia Ohio Supreme Court Opinion Summaries

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

In 2010, Defendant was indicted in Ashland County on charges of theft and breaking and entering. At the time, Defendant was being held in a county jail in Maryland. In 2012, the State re-indicted Defendant. Defendant filed a motion to dismiss the new indictment, arguing that his speedy-trial rights were violated because the applicable time limits under the Interstate Agreement on Detainers (IAD) - codified in Ohio Rev. Code 2963.30 - were exceeded without resolution of the charges. The trial court overruled Defendant’s motion to dismiss, concluding that the time limits under the IAD did not apply because Black was incarcerated in an out-of-state county jail and not in a state penal or correctional institution. Defendant was ultimately convicted of two misdemeanor counts of theft and one felony count of breaking and entering. The court of appeals reversed, holding that the IAD applied to Defendant even though he was incarcerated in an out-of-state county facility. The Supreme Court affirmed, holding that the term “penal or correctional institution of a party state,” as it is used in section 2963.30, includes a county jail as well as a state prison or correctional facility. View "State v. Black" on Justia Law

These three consolidated cases arose out of the same set of facts and raised identical issues. Pursuant to a search warrant issued by a probate judge, which gave law enforcement permission to search a business for evidence of illegal gambling, more than thirty video slot machines were confiscated, giving rise to charges filed against Defendants, who were operating the business. Defendants moved to suppress the evidence, asserting that the search warrant was void because probate judges do not have the statutory authority to issue a criminal search warrant. The trial court agreed with Defendants and granted the motions to suppress the evidence gathered to the tainted warrant. The court of appeals reversed, holding (1) the probate judge did indeed lack authority to issue a search warrant; but (2) the police officers acted in good-faith reliance on the warrant under United States v. Leon. The Supreme Court affirmed, holding (1) a probate judge does not have the authority to issue search warrants in criminal matters; and (2) the good-faith exception to the exclusionary rule set forth in Leon applies in these cases. View "State v. Brown" on Justia Law

A law enforcement officer sought a warrant to search a house based on facts within the supporting affidavit. Among those facts were the results of a “trash pull” that detectives had conducted outside the house. Based on these facts, the officers obtained the search warrant and, upon executing the warrant, found evidence of an active methamphetamine lab. Defendant was indicted on eight felony counts related to the manufacturing, possession, and trafficking of drugs. Defendant moved to suppress the evidence discovered through execution of the search warrant. The trial court granted the motion, concluding that “one trash pull is not necessarily sufficient” to establish probable cause. The court of appeals affirmed. The Supreme Court reversed, holding that, under the totality of the circumstances, the evidence seized from the single trash pull that corroborated tips and background information involving drug activity was sufficient to establish probable cause for a warrant. Remanded. View "State v. Jones" 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