Justia Ohio Supreme Court Opinion Summaries

After a jury trial, Appellee was convicted of one count of rape and one count of kidnapping. The court of appeals vacated both convictions, holding that the State failed to present sufficient evidence showing Appellee knew or had reason to know that the alleged victim's ability to consent was substantially impaired. Upon his release, Appellee filed an action for declaratory judgment seeking compensation from the State for wrongful imprisonment. The trial court granted Appellee's motion for summary judgment, finding that Appellee was innocent of the charges upon which he was convicted, or that no crime was committed by Appellee, or both. The court of appeals affirmed. The Supreme Court reversed, holding (1) one who claims to be a "wrongfully imprisoned individual" under Ohio Rev. Code 2743.48 must prove all of the factors in section 2743.48(A) by a preponderance of the evidence before seeking compensation from the State for wrongful imprisonment; and (2) a trial court adjudicating proof of innocence pursuant to section 2743.48(A)(5) may not find that a claimant has been wrongfully imprisoned based solely on an appellee court judgment vacating a felony conviction due to insufficient evidence and discharging the prisoner without a remand for a new trial. Remanded. View "Doss v. State" on Justia Law

Defendant appealed from a judgment of the court of appeals that affirmed his classification as a Tier I sex offender based on his guilty plea to one count of sexual imposition. At issue was whether the trial court retained authority to classify Defendant as a Teir I sex offender more than a year after the entry of a final judgment of conviction for a sexually oriented offense. The Supreme Court reversed, holding that the trial court lacked authority to reopen this case to reconsider the final judgment it had entered, and the protections against double jeopardy barred it from classifying Defendant as a Tier I sex offender more than a year after it imposed sentence. View "State v. Raber" on Justia Law

This was an original action by Relators, property owners, for a writ of mandamus to compel Respondents, the Department of Natural Resources and its director, to initiate appropriation proceedings for the physical taking of their property resulting from flooding caused by a spillway constructed by Respondents and the state's lake-level-management practices. On December 1, 2011, the court granted a writ of mandamus to compel Respondents to commence appropriation proceedings to determine the amount of their taking of the property. Following failed settlement negotiations, the State filed appropriation cases for the property of two of the relators. All of the relators with the exception of the two then filed a motion for an order for Respondents to show cause why they should not be held in contempt of the court's December 1, 2011 writ. The Supreme Court held that Relators established by clear and convincing evidence that Respondents were in contempt of the court's December 1, 2011 writ and ordered Respondents to file appropriation cases for Respondents' parcels. View "State ex rel. Doner v. Zehringer" on Justia Law

A grand jury issued an indictment charging Appellee with two counts of trafficking in drugs. Appellee filed a motion to dismiss, alleging that the indictment did not sufficiently charge the two trafficking counts because neither count named the specific controlled substance involved. The trial court denied Appellee's motion, and Appellee pleaded no contest to the charges. Appellee appealed, and the court of appeals reversed, holding that the indictment was insufficient because it stated that the drug involved was a Schedule I or II drug instead of naming the specific drug involved. The Supreme Court reversed, holding (1) an indictment charging a defendant with trafficking in drugs under Ohio Rev. Code 2925.03 is sufficient if it names the schedule in which the drug appears; and (2) therefore, the indictment in this case adequately informed Defendant of the charges pending against him. View "State v. Jackson" on Justia Law

At issue in this case was whether, in general, cell-phone records produced by a cell-phone company constitute testimonial evidence that implicates a defendant's right to cross-examine a witness under the Confrontation Clause of the Sixth Amendment. Defendant here was convicted of murder, kidnapping, aggravated robbery, and aggravated burglary. Defendant appealed, arguing that the trial court had erred by allowing cell phone records to be admitted into evidence without being properly authenticated in violation of the Confrontation Clause. The appellate court determined that the admission of the cell-phone records did not contribute to Defendant's conviction and affirmed the judgment of the trial court. The Supreme Court affirmed, holding (1) because cell-phone records are generally business records that are not prepared for litigation and are thus not testimonial, the Confrontation Clause does not affect their admissibility; (2) however, the hearsay rule barred the records' admission in this case because they were not properly authenticated; but (3) the admission of the cell-phone records did not contribute to Defendant's conviction, and their admission was harmless beyond a reasonable doubt. View "State v. Hood" on Justia Law

In this certified conflict, the Supreme Court considered whether a trial court's failure to impose the statutorily mandated fine required by Ohio Rev. Code 2925.11(E)(1)(a) and 2929.18(B)(1) when no affidavit of indigency has been filed with the court prior to the trial court's journal entry of sentencing renders void the part of the sentence waiving the fine. The Supreme Court affirmed the judgment of the court of appeals in resolving the certified conflict, holding that a trial court's failure to impose the required fine under these circumstances renders void the part of the sentence waiving the fine, and that resentencing of the offender is limited to the imposition of the mandatory fine. View "State v. Moore" on Justia Law

This was an original action challenging the decennial apportionment of districts in the General Assembly. At issue was whether the 2011 apportionment plan adopted by the apportionment board (Respondents) complied with Ohio Const. art. XI, 7 and 11. The Supreme Court denied Relators' request for declaratory and injunctive relief, holding that Relators failed to adduce sufficient, credible proof to rebut the presumed constitutionality accorded the 2011 apportionment plan by establishing that the plan was unconstitutional beyond a reasonable doubt, and therefore, Relators were not entitled to a declaration that the 2011 apportionment plan was unconstitutional or a prohibitory injunction to prevent elections from being conducted in accordance with that plan. View "Wilson v. Kasich" on Justia Law

In this appeal, the Supreme Court was asked to determined whether Ohio Const. art. XII, 5a permits the use of motor vehicle and gas tax (MVGT) funds to pay those costs of a county's joint self-insurance pool attributable to covering the risk of liability and loss resulting from the operations of a county engineer's highway department. The Supreme Court concluded that Ohio Const. art. XII, 5a authorizes the use of MVGT funds to pay a county's cost of participating in a joint self-insurance pool attributable to covering the risk of liability and loss resulting from the operations of a county engineer's highway department. In so holding, the Court reversed the judgment of the court of appeals and remanded. View "Stockberger v. Henry" on Justia Law

Appellant, the former mayor of the city of Vermilion, appealed from a judgment denying her request for a writ of mandamus to compel Appellee, the city, to provide copies of certain itemized billing statements for attorney services rendered to the city. Because she thought the annual legal fees expended by the new administration would far exceed the fees incurred during her administration, Appellant made the records requests to permit public scrutiny of the city's expenditure of funds for legal services. The Supreme Court (1) reversed the portion of the court of appeals granting summary judgment in favor of the city and denying Appellant's claim for a writ of mandamus, as the city did not establish that the entirety of the requested statements were exempt from disclosure under the Public Records Act; and (2) affirmed the portion of the judgment denying Appellant's request for an award of statutory damages and attorney fees. Remanded. View "State ex rel. Anderson v. City of Vermilion" on Justia Law

In this case, the Supreme Court considered whether Appellant, Ohio Department of Jobs and Family Services (ODJFS), properly denied applications for federal wage subsidies filed by Appellees, three former employees of American Standard who later were reemployed at a lower wage before they reached the age of fifty. The Ohio Unemployment Compensation Review Commission denied Appellees' eligibility for the subsidies. The court of common pleas reversed. The Supreme Court reversed and remanded, holding that because ODJFS offered a reasonable interpretation of ambiguous language in the federal statute that established the wage subsidies, ODJFS did not improperly deny the applications. View "Lang v. Dir., Ohio Dep't of Job & Family Servs." on Justia Law