Justia Ohio Supreme Court Opinion Summaries

After a car accident involving David Fraley and Timothy Oeding, Oeding’s insurer (“Auto-Owners”) placed an investigative hold on Fraley’s truck for several months. Fraley filed a negligence action against Oeding’s estate, Oeding’s employer (“J&R”), and Auto-Owners, alleging, among other things, that Auto-Owners’ investigatory hold caused Fraley intangible economic loss due to the loss of use of the truck. The trial court dismissed the complaint, holding (1) the court could not exercise personal jurisdiction over Oeding and J&R solely because their insurer did business in Ohio, and (2) Fraley was not entitled to maintain a direct action against Auto-Owners because he had not obtained a judgment against Auto-Owners’ insureds. The court of appeals reversed, concluding that the trial court erred in its determination that it lacked personal jurisdiction over Oeding and J&R because Auto-Owners’ investigatory hold and its communication with Fraley brought Auto-Owners, and by extension J&R and Oeding, within Ohio’s long-arm statute. The Supreme Court reversed, holding that an Ohio court may not impute an insurance company’s conduct to its nonresident insured for purposes of establishing personal jurisdiction over the insured. View "Fraley v. Estate of Oeding" on Justia Law

At issue in this case was Ohio Rev. Code 4921.25, which grants the Public Utilities Commission of Ohio (PUCO) authority to regulate towing companies as “for-hire motor carriers.” The City of Cleveland filed an action seeking a declaration that the statute violated the Home Rule Amendment of the Ohio Constitution because it was a general law that displaced municipal tow truck ordinances. The trial court granted summary judgment to the State, determining that the statute was a general law that does not violate the Constitution by infringing on the City’s home rule authority. The court of appeals reversed, concluding that the statute was not a general law and therefore unconstitutionally attempted to limit municipal home-rule authority. The Supreme Court affirmed in part and reversed in part, holding (1) the second sentence of the statute violates the Home Rule Amendment by prohibiting the “licensing, registering, or regulation” of entities that tow motor vehicles and so will be severed; but (2) the first sentence of the statute is a general law. View "Cleveland v. State" on Justia Law

Defendant was charged with felony domestic violence, which contained an allegation that Defendant had been previously convicted of two offenses of domestic violence. After a jury trial, Defendant was convicted of domestic violence as charged. The appellate court reversed Defendant’s conviction, determining that the state failed to establish the necessary element of Defendant’s prior domestic violence convictions. The Supreme Court reversed the judgment of the appellate court and reinstated the judgment of the trial court, holding that because, during trial, the defense stipulated to the authenticity of Defendant’s two prior first degree misdemeanor domestic violence convictions, the state did properly prove the instant conviction. View "State v. Tate" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of sexually-related crimes arising from incidents involving underage boys, including rape and gross sexual imposition. Defendant appealed, arguing, among other things, that his confrontation rights were violated when he was not allowed to cross-examine Mark Losko with the Bureau of Criminal Identification and Investigation (BCI) because Losko was not called to testify at trial regarding the DNA profile he created for Defendant and the alleged victims. The court of appeals affirmed the judgment of the trial court, concluding that because Losko's report contained only raw data and because Kristen Slaper, a BCI forensic analyst, testified and was cross-examined regarding her own report linking Defendant to the incriminating DNA evidence, Defendant's Sixth Amendment rights had not been violated. The Supreme Court affirmed, holding (1) when a defendant has stipulated to the admissibility and content of a nontestifying analyst's scientific report, the testimony of a witness who relied on that report does not violate the defendant's right to confrontation; and (2) because Defendant stipulated to Losko's report, he waived any later Confrontation Clause challenge to the use of the report by other witnesses. View "State v. Keck" on Justia Law

Defendant was convicted of failure to comply with a police officer and obstruction of official business. The trial court imposed separate sentences for the two offenses. Defendant appealed, arguing that the offenses should have merged at sentencing as allied offenses of similar import under Ohio Rev. Code 2941.25. The appellate court remanded for a determination as to whether the offenses were allied offenses under State v. Johnson, which instructs courts that a defendant's conduct "must be considered" when determining whether multiple offenses merge at sentencing pursuant to section 2941.25. The trial court determined that the offenses were not allied offenses of similar import and imposed separate prison terms for the two offenses. The court of appeals reversed, concluding that Defendant's sentences merged under Johnson because they were based on the same conduct. The Supreme Court reversed, holding (1) when deciding whether to merge multiple offenses at sentencing pursuant to section 2941.25, a court must review the entire record to determine whether the offenses were committed separately or with a separate animus; and (2) the court of appeals erred by relying on Johnson for the proposition that a court may consider a defendant's conduct only as it was described by the state's theory at trial. View "State v. Washington" on Justia Law

Ramona Whitley and Debra Jones, teachers at a preschool day care, questioned three-year-old L.P. about an eye injury and marks on his face upon his arrival at the preschool. Whitley reported suspected child abuse after L.P. identified Defendant as responsible for his injuries. A grand jury subsequently indicted Defendant of several counts of felonious assault, endangering children, and domestic violence. After a jury trial, Defendant was convicted of all charges except one felonious assault count. The court of appeals reversed Defendant's convictions and remanded for a new trial, holding that the trial court abused its discretion by permitting the preschool teachers to testify regarding L.P.'s statements in violation of the Confrontation Clause. The Supreme Court affirmed, holding (1) statements elicited from a child by a teacher in the absence of an ongoing emergency and for the primary purpose of gathering information of criminal conduct and identifying the alleged perpetrator of suspected child abuse are testimonial in nature; and (2) therefore, the admission of L.P.'s statements violated Defendant's right to confrontation. View "State v. Clark" on Justia Law

Petitioner pled guilty to various drug and weapons offenses and was sentenced to five years' imprisonment. On February 17, the trial court issued an order granting 1,530 days of jail-time credit. On February 18, however, the court set aside the February 17 entry on the grounds that it had been inadvertent. Petitioner was ultimately resentenced to concurrent five-year sentences for the remaining offenses with 964 days of jail-time credit. Petitioner subsequently made the February 17 and February 18 entries the subject of numerous proceedings, including a habeas action, in which he claimed that he was entitled to the jail-time credit awarded him in the February 17 entry. Petitioner then filed this petition for a writ of habeas corpus, making the same claim advanced in his earlier habeas petition. The Supreme Court dismissed the habeas action, holding (1) Petitioner had alternate remedies in the ordinary course of law to pursue relief on his claim; (2) res judicata barred Petitioner's claim; and (3) Petitioner's claim was invalid on the merits. View "Pruitt v. Cook" on Justia Law

Defendant was convicted of two counts each of aggravated murder, attempted murder, and aggravated robbery. The trial court imposed capital punishment for aggravated murder an an aggregate term of twenty-six years' imprisonment for the noncapital offenses. The Supreme Court (1) reversed one of Defendant's aggravated murder convictions, the specifications related to that count, and the specification associated with the other aggravated murder charge because each of these counts and specifications required proof that Defendant was under detention at the time of the murder, and the original sentencing entry that placed Defendant under detention was void; and (2) affirmed the remaining convictions, the imposition of capital punishment in the other aggravated murder count, and the imposition of consecutive terms of imprisonment on the noncapital offense convictions. View "State v. Wesson" on Justia Law

After a jury trial, Appellant was convicted of aggravated murder and sentenced to death. The Supreme Court vacated the death sentence and remanded for resentencing. On remand, the trial court again sentenced Appellant to death. The Supreme Court against vacated Appellant's sentence of death, holding that, under the unique circumstances of this case, the trial court failed to consider relevant mitigating evidence contained in Appellant's allocution in sentencing her to death, and therefore, the court erred in sentencing Appellant to death. Remanded for consideration of Appellant's allocution when weighing the aggravating circumstances and the mitigating factors during resentencing. View "State v. Roberts" on Justia Law

Between 1987 and 2007, Appellant was convicted six times for different offenses. In 2007, the Governor granted a pardon for four of those convictions. Appellant subsequently sought to seal the records of three of the pardoned convictions. The lower courts denied Appellant's requests. The court of appeals affirmed, holding that Appellant was not entitled to have her record of conviction sealed solely by virtue of the pardon. The Supreme Court affirmed, holding that, in absence of a statutory provision requiring the sealing of a criminal record based on a pardon, a gubernatorial pardon does not automatically entitle the recipient to have the record of the pardoned conviction sealed. View "State v. Boykin" on Justia Law