Justia Ohio Supreme Court Opinion Summaries

In 2008, the City of Toledo enacted an ordinance authorizing an automated traffic-law-enforcement system that assesses civil penalties against a vehicle’s owner for speeding and red-light violations. The ordinance further provides that appeals are heard through an administrative process established by the Toledo police department. Appellee received a notice of liability for a traffic violation under the ordinance and paid the civil penalty without pursuing an administrative appeal. Appellee then filed a class-action complaint against the City for unjust enrichment, asserting that the ordinance was unconstitutional. The trial court dismissed the complaint. The Court of Appeals reversed, holding that the ordinance was unconstitutional because it usurped the jurisdiction of the municipal court. The Supreme Court reversed, holding (1) the Ohio Constitution and statutory law do not endow municipal courts with exclusive authority over traffic-ordinance violations; and (2) Ohio municipalities have home rule-authority to impose civil liability on traffic violators through an administrative enforcement system and to establish administrative proceedings that must be exhausted before offenders can pursue judicial remedies. View "Walker v. Toledo" on Justia Law

Following a jury trial, Defendant was convicted of the aggravated murders of his girlfriend and two children. The trial court sentenced Defendant to death. The Supreme Court affirmed. The Supreme Court affirmed the convictions and sentence of death, holding (1) the prosecutor did not violate Batson v. Kentucky during voir dire; (2) while the prosecutor made improper comments, the improper comments were not prejudicial and did not deny Defendant a fair trial; (3) the trial court did not err in admitting surveillance videos into evidence; (4) the evidence was sufficient to sustain Defendant’s convictions; (5) Defendant’s counsel did not provide ineffective assistance during either phase of trial; and (6) the death penalty was appropriate and proportionate when compared to death sentences approved in similar cases. View "State v. Pickens" on Justia Law

In 2008, A police detective placed a global-positioning-system (GPS) tracking device on Defendant’s vehicle without obtaining a search warrant. Based on information gathered using the GPS device, law enforcement officers indicted Defendant for drug-related charges. Defendant moved to suppress the evidence, arguing that the warrantless placement and monitoring of the GPS tracking device on his vehicle violated his Fourth Amendment rights. The trial court denied the motion to suppress. The Supreme Court remanded to the trial court for application of United States v. Jones, decided in 2012, which held that attaching a GPS tracking device to an individual’s vehicle is a search within the meaning of the Fourth Amendment. On remand, the trial court found that placing the GPS device on Defendant’s van violated the Fourth Amendment but that the good-faith exception to the exclusionary rule applied. The Supreme Court affirmed, holding because binding appellate precedent justified placing GPS tracking devices on suspects’ vehicles without obtaining a search warrant at the time of the facts giving rise to this case, the good-faith exception to the exclusionary rule applied and exclusion of the evidence obtained by police in this case was not warranted. View "State v. Johnson" on Justia Law

Defendant was arrested pursuant to three misdemeanor arrest warrants. Based on information collected upon the execution of the arrest warrants, Defendant was charged with aggravated murder and aggravated robbery. Defendant filed a motion to suppress all evidence collected as a result of his arrest, contending that the arresting officers lacked a valid warrant to arrest him because no probable-cause determination was made before the warrants were issued and because the criminal complaints on which the warrants were based contained no information that would support a finding of probable cause. The trial court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the lower courts correctly determined that the warrants were issued improperly because there was no determination of probable cause; and (2) the remedy of suppression of the evidence obtained pursuant to the defective warrants was not available because the officers relied in good faith upon a procedure established in binding precedent. View "State v. Hoffman" on Justia Law

After a jury trial, Appellee was convicted of, inter alia, engaging in a pattern of corrupt activity. Appellee’s convictions were affirmed on appeal. The court of appeals reversed the conviction for engaging in a pattern of corrupt activity, concluding that Appellee’s appellate counsel had been ineffective for failing to challenge the jury instructions defining the term “enterprise,” as the jury instructions had been inadequate. The Supreme Court reversed, holding that the jury instructions, when read and understood together, adequately conveyed the law regarding the term “enterprise” and that the jury was appropriately and adequately informed on the issue. View "State v. Griffin" on Justia Law

After a jury trial, Appellant was sentenced to death for the aggravated murder of a police officer. The Supreme Court affirmed Appellant’s convictions and sentence of death, holding (1) the trial court did not err by overruling Appellant’s objection to the State’s peremptory challenge, and the court conducted an adequate voir dire; (2) the trial court did not err by denying Appellant’s motion for a change of venue; (3) the trial court did not commit prejudicial error in its evidentiary rulings or in its instructions to the jury; (4) any questionable conduct that the prosecutor engaged in during the proceedings did not deprive Appellant of a fair trial; (5) Appellant’s counsel provided constitutionally effective assistance; and (6) Appellant’s challenges to the death penalty failed, and the death sentence was appropriate and proportionate in this case. View "State v. Thompson" on Justia Law

The City of Cincinnati charged Daniel Ilg with operating a vehicle while under the influence of alcohol and related offenses. Ilg moved to suppress the results of his breath test taken from an Intoxilyzer 8000 machine. During discovery, Ilg sought computerized online breath archives data consisting of information transmitted by the specific machine used to test him to the Ohio Department of Health (ODH) for each breath test it performed. Ilg sought the data to challenge whether the Intoxilyzer 8000 machine operated properly on the day of his arrest. When the information was not forthcoming, the trial court ordered ODH to disclose the records. The ODH failed to comply with the discovery order, and the trial court ordered as a sanction that the evidence obtained from the Intoxilyzer 8000 be excluded from trial. The Supreme Court affirmed, holding that the sanction was warranted in this case because Ilg was entitled to discovery of relevant evidence to support his claim that the Intoxilyzer 8000 machine used to test him failed to operate properly. View "City of Cincinnati v. Ilg" on Justia Law

Defendant was indicted on two counts of aggravated murder, each of which carried three death specifications. Defendant waived a jury and was tried by a three-judge panel. The panel found Defendant guilty of felony murder and sentenced him to death. The Supreme Court affirmed, holding (1) Defendant’s jury waiver and voluntary, knowing, and intelligent; (2) the procedure whereby the judges were appointed to the panel was not plain error; (3) Defendant’s confession was voluntary; (4) Defendant’s claim that the State violated his Sixth Amendment rights by seizing “attorney work product” during a search of his jail cell was waived at trial; (5) prosecutorial misconduct did not deny Defendant a fair trial; (6) the aggravating circumstances outweighed the mitigating factors in this case beyond a reasonable doubt; and (7) the death sentence in this case was appropriate and proportionate.View "State v. Osie" on Justia Law

Stanley and Kathryn Wasserman are the successors in interest to an easement created in 1915 for the purpose of draining what is now their farmland over land now owned by the City of Freemont. After the City unilaterally replaced plastic drainage tiles across the easement with a single drainage pipe and rerouted the drainage pathway, the Wassermans sued in mandamus, alleging an unconstitutional taking. The court of appeals concluded that the City violated the easement and that the Wassermans were entitled to a determination of whether a taking had actually occurred. The Supreme Court reversed, holding (1) the express easement language gave the owner of the original servient estate the right to determine the lines by which the drainage system should run through the land, and as the current owner of the servient estate, the City retained the right to change the route of the drainage tile as long as it continued to drain the Wassermans’ land; and (2) under the facts of this case, the City did not violate the easement.View "State ex rel. Wasserman v. City of Fremont" on Justia Law

Article I, Section 9 of the Ohio Constitution provides that “[a]ll persons shall be bailable by sufficient sureties.” Under Crim.R. 46(A)(2), however, a court may require a defendant to post ten percent of the bail amount in cash. Relators in these consolidated cases were bail bond agents and companies seeking writs of mandamus to compel the clerk and judges of county courts to accept surety bonds in all cases where bail is set by the court. Relator Woody Fox Bail Bonds also requested damages. The Supreme Court granted the requested writs of mandamus but denied damages, holding (1) Crim.R. 46(A)(2) is unconstitutional insofar as it permits a court to require a bond secured by a ten percent cash deposit as the only option, to the exclusion of a surety bond, because it denies the constitutional rights of defendants to be “bailable by sufficient sureties”; and (2) the clerk of courts and judges have political-subdivision immunity.View "State ex rel. Sylvester v. Neal" on Justia Law