Justia Ohio Supreme Court Opinion Summaries

Defendant pled guilty to the murders of two women and to two counts of abuse of a corpse. After a jury trial, Defendant was convicted of aggravated murder with death specifications for the deaths of two girls. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding, primarily, that (1) the State’s closing remarks in the penalty phase were “improper and substantially prejudicial,” but the Court’s independent evaluation and approval of the capital sentence cured the errors in the penalty-phase proceedings; (2) the trial court did not violate Ohio R. Evid. 404(B) by allowing a witness to testify that when she was thirteen years old Defendant exposed himself to her and offered her five dollars to engage in oral sex; (3) trial counsel did not render ineffective assistance; (4) the State presented sufficient evidence to convict Defendant of attempted rape or robbery in connection the murder of one of the girls; and (5) the sentence was appropriate.View "State v. Kirkland" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated murder and sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in finding that Appellant was competent to stand trial; (2) the trial court did not abuse its discretion in ordering Appellant to wear leg restraints in the courtroom, and even assuming that the order was an abuse of discretion, the error was harmless; (3) the trial court erred in allowing the State to introduce evidence of weapons and ammunition not used in the murders, but the error was harmless; (4) the trial court did not abuse its discretion in introducing the former testimony of Dr. Delaney Smith, a psychiatrist, during the penalty phase, as defense counsel had a prior opportunity to cross-examine Dr. Smith; and (5) the trial court’s sentencing opinion was adequate. View "State v. Neyland" on Justia Law

Appellant pled guilty to multiple criminal offenses, both state and federal. Appellant sought release from prison, arguing that the sentencing entry was ambiguous regarding whether his state sentences were to be served concurrently or consecutively to his federal sentence, and as a result, the sentences must be concurrent. The court of appeals dismissed Appellant’s petition for habeas corpus. The Supreme Court affirmed, holding (1) habeas corpus was inappropriate in this case because sentencing errors are not cognizable in habeas corpus; (2) the availability of other adequate remedies at law also precludes relief in habeas corpus; and (3) even if Appellant could overcome the problems with habeas in this case, his arguments were without merit because the sentencing entry was not ambiguous. View "State ex rel. O’'Neal v. Bunting" on Justia Law

Defendant was a juvenile when he committed acts constituting aggravated robbery. After a mandatory bindover hearing, the juvenile court relinquished jurisdiction and transferred the matter to the common pleas court. Defendant did not object to the mandatory bindover. Defendant then pleaded guilty to one count of aggravated robbery with a firearm specification. Defendant was sentenced to four years in prison. Defendant appealed, arguing, for the first time, that the statutory mandatory bindover procedures violated his constitutional rights and that defense counsel provided ineffective assistance by failing to raise these claims in the lower courts. The court of appeals affirmed, holding that, by pleading guilty, Defendant had waived his right to challenge either the mandatory bindover or his attorney’s failure to object to it and that Defendant had not demonstrated that his counsel provided ineffective assistance. The Supreme Court affirmed, holding that Defendant forfeited his challenge to the constitutionality of the mandatory bindover statutes by failing to present it to the lower courts. View "State v. Quarterman" on Justia Law

After a jury trial, Defendant was found guilty of felonious assault and carrying a concealed weapon. The appellate court remanded the matter for resentencing, determining that the trial court did not properly impose postrelease control. At the resentencing hearing, Defendant told the trial court that he wanted to represent himself. Thereafter, the court announced that Defendant would be subject to mandatory postrelease control upon release from prison. Defendant appealed, arguing that his right to counsel was violated during the resentencing proceedings and that a resentencing hearing is a critical stage of a criminal proceeding to which the right to counsel attaches. The appellate court affirmed, holding that the trial court had not violated Defendant’s right to counsel by allowing him to represent himself at the resentencing hearing. The Supreme Court affirmed, holding (1) a resentencing hearing is a critical stage of the proceedings to which the right to counsel attaches; and (2) Defendant knowingly, intelligently, and voluntarily waived his right to counsel at the resentencing hearing. View "State v. Schleiger" on Justia Law

After a group of Richmond Heights, Ohio electors submitted a “recall petition” to recall Mayor Miesha Wilson Headen, the Richmond Heights City Council voted to certify the mayoral recall issue for inclusion on the ballot. A special election was scheduled for September 23, 2014, and early voting in the special election began on August 27, 2014. On September 4, 2014, James G. Dawson attempted to file a written protest against the special election. The Cuyahoga County Board of Elections refused to accept the protest because the voting had already begun. Dawson subsequently filed suit seeking a writ of prohibition against the Board of Elections to prevent it from submitting the recall initiative to the voters at the September 23, 2014 special election. The Supreme Court denied the writ, holding that Dawson failed to present any reason why a writ of prohibition should issue to prevent the recall election. View "State ex rel. Dawson v. Cuyahoga County Bd. of Elections" on Justia Law

On August 5, 2014, Relators submitted a petition to the clerk of council to amend the charter of the City of Maple Heights by limiting the use of photo-monitoring devices to enforce traffic laws. On August 18, 2014, the director of the Cuyahoga County Board of Elections certified that the part-petitions contained sufficient valid signatures to qualify for the ballot. The city council, however, took no action on the petition. On August 25, 2014, Relators this expedited election action in the Supreme Court for a writ of mandamus to compel the City and its city council to pass an ordinance placing the charter-amendment initiative on the November 4, 2014 ballot. On September 3, 2014, council referred the matter to the Committee as a whole but failed to schedule a vote on the matter. The Supreme Court granted the writ, as the city council failed to submit the charter-amendment initiative “forthwith” as required by the Ohio Constitution. View "State ex rel. Comm. for Charter Amendment Petition v. City of Maple Heights" on Justia Law

Thomas Brown ran unsuccessfully to become the Democratic nominee for a seat on the Ashtabula County common pleas court in the Democratic Party primary election. Brown subsequently filed nominating petitions to be a judicial candidate on the Ashtabula County Western Area Court in the general election. The Ashtabula County Board of Elections (Board) rejected Brown’s petitions based on the ballot-access restrictions set forth in Ohio Rev. Code 3513.04. Relators, including Brown, subsequently sought a writ of mandamus compelling the Board and its director (collectively, Respondents) to certify Brown’s candidacy for the Western Area Court, asserting that section 3513.04 is unconstitutional. The Supreme Court denied the writ, holding that Relators failed to overcome the presumption of constitutionality and failed to demonstrate that section 3513.04 is unconstitutional beyond a reasonable doubt. View "State ex rel. Brown v. Ashtabula County Bd. of Elections" on Justia Law

After a jury trial, Defendant was found guilty of the aggravated murder of Nichole McCorkle and sentenced to death. The Supreme Court affirmed the judgment of conviction and the sentence of death, holding, among other things, that (1) the trial court did not err in admitting the autopsy report on McCorkle and by allowing a medical examiner, who did not conduct the autopsy, to testify about the autopsy results because an autopsy report that is neither prepared for the primary purpose of accusing a targeted individual nor prepared for the primary purpose of providing evidence in a criminal trial is nontestimonial and its admission into evidence at trial as a business record does not violate a defendant’s Sixth Amendment confrontation rights; (2) trial counsel did not provide constitutionally ineffective assistance; and (3) the trial court did not err by failing to appoint a neurologist to develop mitigation.View "State v. Maxwell" on Justia Law

Defendant was convicted of three counts of aggravated murder and other felony offenses. The Supreme Court affirmed Defendant’s convictions and sentence of death, holding (1) even if the trial court overstepped its bounds in conducting an Adkins hearing, no prejudice occurred; (2) Defendant’s waiver of a jury trial was voluntary, knowing, and intelligent; (3) the prosecutor did not engage in misconduct; (4) Defendant’s counsel provided constitutionally effective assistance; (5) the three-judge panel did not violate Defendant’s constitutional rights by choosing to give certain mitigating evidence no weight and limited weight; and (6) Defendant’s remaining claims similarly failed. View "State v. Jackson" on Justia Law